# WYOMING STATE IMPLEMENTATION PLAN

Regional Haze

Addressing Regional Haze Requirements for Wyoming Mandatory Federal Class I Areas Under 40 CFR 51.309(g)

Grand Teton National Park

Yellowstone National Park Bridger Wilderness Fitzpatrick Wilderness

North Absaroka Wilderness

Teton Wilderness

Washakie Wilderness

January 7 , 2011

Prepared By

The Wyoming Department of Environmental Quality Air Quality Division Herschler Building, 122 West 25 th 

### Street Cheyenne, Wyoming 82002i 

### Table of Contents

Page

Chapter 1

. General Plan Provisions ............................................................................................1

Chapter 2 . Wyoming Class I Areas ; Baseline, Natural and Current Visibility Conditions ..3

2.1 Description of the Yellowstone Monitoring Site (YELL2) Class I Areas ....................3

2.1.1 Grand Teton National Park ............................................................................3

2.1.2 Tet on Wilderness ...........................................................................................5

2.1.3 Yellowstone National Park ............................................................................7

2.1.4 Mo nitoring Strategy and Location - YELL2 Monitoring Site .......................8

2.1.5 Assessment of Baseline, Natural and Current Conditions - YELL2

Class I Areas ................................................................................................10

2.2 Description of the North Absaroka Mon itoring Site (NOAB1) Class I Areas ...........13

2.2.1 North Absaroka Wilderness .........................................................................13

2.2.2 Washakie Wilderness ...................................................................................15

2.2.3 Mo nitoring Strategy and Location

- NOAB1 Monitoring Site ....................16

2.2.4 Assessment of Baseline, Natural and Current C onditions - NOAB1

Class I Areas ................................................................................................18

2.3 Description of the Bridger Monitoring Site (BRID1) Class I Areas ..........................21

2.3.1 Bridger Wilderness ......................................................................................21

2.3. 2 Fitzpatrick Wilderness .................................................................................23

2.3.3 Mon itoring Strategy and Location - BRID1 Monitoring Site ......................24

2.3.4 Assessment of Baseline, Natural an d Current Conditions - BRID1

Class I Areas ................................................................................................26

Chapter 3 . Pollutants Causing Visibility Impairment in Wyoming Class I Areas ...............29

3.1 Yellowstone National Park, Grand Teton National Park and Teton Wilderness ........32

3.2 North Absaroka and Washakie Wil derness Areas ......................................................35 3.3 Bridger and Fitzpatrick Wilderness Areas ..................................................................37

Chapter 4

. Statewide Emission Inventory ................................................................................40

4.1 Introduction .................................................................................................................40

4.2 SO

x Emission Inventory ..............................................................................................41

4.3 NO

x Emission Inventory .............................................................................................42 4.4 OC Emission Inventory...............................................................................................43 4.5 EC Emission Inventory ...............................................................................................44 4.6 Fine PM Emission Inventory ......................................................................................45 4.7 Coarse PM Emission Inventory ..................................................................................46

4.8 Ammonia Emission Inventory ....................................................................................47 4.9 Inventories Utilized For Emissions Projections ..........................................................47

4.10 PRP18b ................................

................................ .....................................................48ii Chapter 5 . Source Apportionment and Regional Haze Modeling ..........................................50

5.1 Overview .....................................................................................................................50 5.1.1 Source Apportionment Analysis - PSAT and WEP .....................................50 5.1.2 Regional Haze Modeling - CMAQ ..............................................................51 5.2 Major Source Categories Contributing to Haze in Wyoming .....................................53 5.2.1 PSAT Regional Contribution to Sulfate on 20% Worst Days .....................54 5.2.2 PSAT Regional Contrib utio n to Sulfate on 20% Best Days ........................57 5.2.3 PSAT Regional Contribution to Nitrate on 20% Worst Days .....................61 5.2.4 PSAT Regional Contribution to Nitrate on 20% Best Days ........................64

5.2.5 WEP Potential Contrib ution to OC on 20% Worst Days ............................67

5.2.6 WEP Potential Contri bution to OC on 20% Best Days ...............................70 5.2.7 WEP Potential Contribution to EC on 20% Worst Days .............................72 5.2.8 WEP Potential Contribution to EC on 20% Best Days ................................74 5.2.9 WEP Potential Contribution to Fine PM on 20% Worst Days ....................76 5.2.10 WEP Potential Contribution to Fine PM on 20% Best Days .....................78 5.2.11 WEP Potential Contribution to Coarse PM on 20% Worst Days ..............80 5.2.12 WEP Potential Contribution to Coarse PM on 20% Best Days .................82 5.3 CMAQ 2018 Projected Visibility Conditions .............................................................84 5.3.1 CMAQ Modeling Breakdown by Pollutant for 20% Worst Days ...............85

Chapter 6. Best Available Retrofit Technology (BART) .........................................................89

6.1 Introduction .................................................................................................................89

6.2 SO 2 : Regional SO 2 Milestone and Backstop Trading Program .................................90 6.3 Overview of Wyoming’s BART Regulations .............................................................92 6.4 SIP BART Requirements From EPA ’ s Regional Haze Rule ......................................92 6.5 Facility Analysis .........................................................................................................99 6.5.1 FMC Wyoming Corp. - Granger Facility ....................................................99 6.5.2 FMC Wyoming Corp. - Gr e en River

- Westvaco Facility ...........................99

6.5.3 General Chemical - Green River Works ....................................................100 6.5.4 PacifiCorp - Jim Bridger Power Plant .......................................................102 6.5.5 PacifiCorp - Dave Johnston Power Plant ...................................................104 6.5.6 PacifiCorp - Naughton Power Plant ...........................................................106

6.5.7 Pac ifiCorp - Wyodak Power Plant .............................................................108 6.5.8 Basin Electric Power Coopera tive

- Laramie River Station ......................109

Chapter 7 . Reasonable Progress Goals ...................................................................................113

7.1 Ov e rview ...................................................................................................................113

7.2 Process for Establish ing Reasonable Progress Goals ...............................................114 7.3 Four Factor Analysis Performed for Wyoming Sources ...........................................115

7.3.1 Detailed Des cription of the Four Factors ...................................................116

7.3.2 Source Selection Pro cess for Four Factor Analysis ...................................117 7.3.3 PacifiCorp Dave Johnston El ectric Generating Station .............................118iii 7.3.4 Mountain Cement Company, Laramie Plant .............................................120 7.3.5 Oil and Gas Exploration and Production Field Operations .......................123 7.4 309 SIP and 309(g) ...................................................................................................127

7.5 Setting Reasonable Progress Goals ...........................................................................127

7.6 Demonstrati on That the RPGs for 20 Percent Best and Worst Days are

Reasonable ................................................................................................................128

Chapter 8 . Long- Term Strategy ..............................................................................................132

8.1 Overview ...................................................................................................................132 8.1.1 Summary of all Anthropogenic Sources of Visibility Impairment Considered in Developing the Long- Term Strat egy ..................................132 8.1.2 Summary of Interstate Transport and Contribution ...................................132

8.1.2.1 Other State s’ Class I Areas Affected by Wyoming Emissions ...132 8.1.2.2 Wyoming Class I Areas Affected by Other States, Nations

and Areas of the World ..............................................................135

8.1.3 Summ ary of Interstate Consultation ..........................................................138 8.1.4 Estimated International and Global Contribution to Wyoming

Class I Areas .............................................................................................138 8.2 Required Factors for the Long- Term Strategy ..........................................................141 8.2.1 Emission Reductions Due to Ongoing Air Pollution Control Programs ...141

8.2.1. 1 New Source Review Program .....................................................141 8.2.1.1.1 Prevention of Significant Deterioration (PSD) Program ........................................................................141 8.2.1.1.2 Minor Source BACT Program .....................................142

8.2.1.2 Title V Operating Permit Program ..............................................142

8.2.1.3 New Source Performance Standards (NSPS) .............................143

8.2.1.4 MACT - HAPs Program .............................................................150

8.2.1.5 Phase I Visibility Rules - Wyoming Reasonably Attributable Visibility Impairment Rules ........................................................160

8.2.1.6 Ongoing Implemen tation of Federal Mobile Source Regulations .................................................................................160 8.2.1.7 Ongoing Implementation of Programs to Meet PM 10 NAAQS ..161 8.2.1.7.1 Nonattainment SIP (PM 10 ) - City of Sheridan .............161

8.2.1.7.2 Natural and Uncontrol lable Sources Program

- Natural

Events Action Plan .......................................................162 8.2.2 Measures to Mitigate the Impacts of Construction Activities ...................163 8.2.3 Emission Limitations and Schedules of Compliance ................................163

8 .2.4 Source Retirement and Replacement Schedules ........................................163 8.2.5 Agricultural and Forestry Smoke Management Techniques .....................164 8.2.6 Enforceability of Wyoming ’s Measures ....................................................165 8.3 Additional Measures in the Long- T erm Strategy .....................................................166

8.3.1 Future Federal Mobile Programs ...............................................................166 8.3.2 Efforts to Address Offshore Shipping........................................................167

8.3.3 Long

- Term Control Strategies for BART Facilities ..................................168iv 8.3.4 Evaluation of Control Strategies for Sources Identified in the Reasonable Progress - Four- Factor Analysis .............................................169

8.3.5 Oil and Gas ................................................................................................169

8.3.6 Projection of the Net Effect on Visibility ..................................................170

Chapter 9. Ongoing Monitoring and Emission Inventory Strategy .....................................178

Chapter 10

. Comp rehensive Periodic Implementation Plan Revisions ...............................181

Chapter 11 . Wyoming Regional Haze SIP Development and Consultation Process ..........182

11.1 State to State Consultation ......................................................................................182

11.2 State and Fede ral Land Manager Coordination ......................................................185

11.3 Tribal Consultation .................................................................................................186

Chapter 12

. Determination of the Adequacy of the Existing Plan .......................................187

Chapter 13 . Technical Information and Data Relied Upon in This Plan ............................188

13.1 The WRAP and Technical Support .........................................................................188 13.2 WRAP Committees and Work Groups ...................................................................188

13.3 WRAP Forums ........................................................................................................191

13.4 WRAP TSS .............................................................................................................193 13.5 IMPROVE Monitoring ...........................................................................................193 13.5.1 Background on IMPROVE Monitoring ...................................................193 13.6 Formula for Reconstructed Light Extinction ..........................................................194 13.7 Wyoming IMPROVE Monitoring Network ...........................................................196

List of Tables

Table 3 -1. IMPROVE Monitor Aerosol Composition ..................................................................30

Tab le 4.2-1. Wyoming SO

x Emiss ion Inventory - 2002 and 2018 ...............................................41 Table 4.3-1. Wyoming NO

x Emiss ion Inventory - 2002 and 2018 ..............................................42

Table 4.4- 1. Wyoming OC Emiss ion Inventory - 2002 and 2018 ................................................43

Table 4.5- 1. Wyoming EC Emiss ion Inventory - 2002 and 2018 ................................................44

Table 4.6- 1. Wyoming Fine PM Emiss ion Inventory - 2002 and 2018 ........................................45 Table 4.7-1. Wyoming Coarse PM Emiss ion Inventory - 2002 and 2018 ....................................46 Table 4.8-1. Wyoming Ammonia Emission Inven tory - 2002 and 2018......................................47 Table 4.9-1. Net Change From PRP18a to PRP18b Emissio n Inventories .................................48 Table 5.3-1. CMAQ Modeling Results for 20% Worst Days and 20% Best Days for Wyoming Class I Areas ...........................................................................................85 Table 5.3.1-1. Pollutant Breakdown on 20% Worst Days for Yellowstone NP, Grand

Teton NP, and Teton Wilderness Area ..................................................................86 Table 5.3.1-2. Pollutant Breakdown on 20% Worst Days for North Absaroka and

Washakie Wilderness Area ....................................................................................87v Table 5.3.1-3. Pollutant Breakdown on 20% Worst Days for Bridger and Fitzpatrick

Wilderness Areas ...................................................................................................88 Table 6.2-1. Regional Sulfur Dioxide Emissions and Milestone Report Summary .....................90

Table 6.2-2. Visibil ity

- Sulfate Extinction Only ..........................................................................91

Table 6.4- 1. BART Deter minations for Wyoming Sources .........................................................94

Table 7 .2-1. 20% Best and Worst Days Baseline, Natural Conditions, and Uniform Rate of Progress G o al for Wyoming Class I Areas ........................................................115

Table 7 .3.3- 1. Estimated Costs of Potential Emission Control Devices for Two Boilers

at the Dave Johnsto n Electr ic Generation Station ................................................119

Table 7 .3.3-2. Estimated Energy and Non- Air Environmental Impacts of Potential

Emission Control Devices for Two Boilers at the Dave Johnston Electric Generating Station ..............................................................................................120

Table 7 .3.4- 1. Estimated Costs of Potential Emission Control Devices for One Cement Kiln at the Mountain Cement Company, Laramie Plant .....................................121

Table 7 .3.4-2. Estimated Energy and Non- Air Environmental Impacts of Potential Emission Control Devices for Kiln #2 at the Mountain Cement Company, Laramie

Plant ....................................................................................................................123

Table 7 .3.5-1. Estimated Costs for Oil and Gas Exploration and Production Equipment ..........126

Table 7 .5-1. Reasonable Progress Goals for 20% Worst Days and 20% Best Days for Wyoming Class I Areas ..........................................................................................128

Table 8 .1.2.1-1. Nitrate Contributi on to Haze in Baseline Years ...............................................134

Table 8 .1.2.1-2. Sulfate Contributi on to Haze in Baseline Years ...............................................135

Table 8.3.6- 1. Class I Area Visibility Summary for YELL2 on 20% Worst Days ....................171

Table 8.3.6- 2. Class I Area Visibility Summary for NOAB1 on 20% Worst Days ...................172

Table 8.3.6- 3. Class I Area Visibility Summary for BRID1 on 20% Worst Days .....................173

Table 8.3.6- 4. Class I Area Visibility Summar y for Y EL L2 on 20% Best Days .......................174

Table 8.3.6- 5. Class I Area Visibility Summar y for NOAB1 on 20% Best Days ......................175

Table 8.3.6- 6. Class I Area Visibility Summar y for BRID1 on 20% Best Days ........................176

Table 9 -1. The Wyoming IMPROVE Monitoring Network .......................................................179

Table 13 .7-1. The Wyomin g IMPROVE Monitoring Network ..................................................196

List of Figures

Figure 2.1-1. National Parks and Wilderness Areas in Wyoming (Class I Areas) .........................3 Figure 2.1.1-1. Mormon Row .........................................................................................................3 Figure 2.1.1-2. Grand Teton NP Class I Boundary .........................................................................4 Figure 2.1.2-1. Gravel Creek in 1996. Burned in giant Huck Fire of 1988 ...................................5 Figure 2.1.2-2. Pendergraft Peak 1991 ...........................................................................................5 Figure 2.1.2-3. Teton Wilderness Class I Boundary .......................................................................6 Figure 2.1.3-1. Hot Pool Near Red Cone Geyser ...........................................................................7 Figure 2.1.3-2. Yellowstone National Park Boundary ....................................................................8 Figure 2.1.4-1. YELL 2 Monitoring Site Location ..........................................................................9 Figure 2.1.4-2. Looking South Toward the YELL2 Monitor .......................................................10 Figure 2.1.5- 1. YELL2 Monitor

- Baseline Best Days .................................................................11 Figure 2.1.5- 2. YELL2 Monitor

- Baseline Worst Days ..............................................................11 Figure 2.1.5- 3. YELL2 Monitor

- Natural Best Days ...................................................................12vi Fig ure 2.1.5- 4. YELL2 Monitor

- Natural Worst Days ................................................................12 Figure 2.2.1-1. Pilot and Index Peaks ...........................................................................................13 Figure 2.2.1-2. North Absaroka Wilderness Boundary ................................................................14 Figure 2.2.2-1. Piney Creek With Part of Carter Mountain at Head of Canyon ...........................15 Figure 2.2.2- 2. Washakie Wi lderness Class I Area Boundary .....................................................16 Figure 2.2.3-1. NOAB1 Monitoring Site ......................................................................................17 Figure 2.2.3-2. Looking South Toward the NOAB1 Monitor ......................................................18 Figure 2.2.4- 1. BRID1 Monitor

- Baseline Best Days ..................................................................19 Figure 2.2.4- 2. BRID1 Monitor

- Baseline Worst Days ...............................................................19 Figure 2.2.4- 3. BRID1 Monitor

- Natural Best Days ...................................................................20 Figure 2.2.4- 4. BRID1 Monitor

- Natural Worst Days .................................................................20 Figure 2.3.1-1. Slide Lake .............................................................................................................21 Figure 2.3.1-2. Bridger Wilderness Monitoring Site and Partial Boundary .................................22 Figure 2.3.1- 3. Bridger Wilderness Boundary ..............................................................................22

Fi gure 2.3.2-1. The Wind Rivers From the Wind River Indian Reservation ................................23 Figure 2.3.2-2. Fitzpatrick Wilderness Class I Boundary .............................................................24 Figure 2.3.3-1. BRID1 Monitoring Site ........................................................................................25 Figure 2.3.3-2. Looking North Toward BRID1 Monitor ..............................................................25 Figure 2.3.4- 1. BRID1 Mon itor

- Baseline Best Days ..................................................................27 Figure 2.3.4- 2. BRID1 Monitor

- Baseline Worst Days ...............................................................27 Figure 2.3.4- 3. BRID1 Monitor

- Natural Best Days ...................................................................28 Figure 2.3.4- 4. BRID1 Monitor

- Natural Worst Days .................................................................28 Figure 3 -1. Light Extinction by Pollutant Species for Wyoming Class I Areas 20% Best Days (2000-2004) ......................................................................................................31 Figure 3 -2. Light Extinction by Pollutant Species for Wyoming Class I Areas 20% Worst Days (2000-2004) ......................................................................................................32 Figure 3.1- 1. Yellowstone IMPROVE Site - Average Pollutant Species Contribution to 20% Best and 20% Worst Days Baseline (2000-2004) ..........................................33 Figure 3.1- 2. Yellowstone IMPROVE Site - Monthly Average Pollutant Species Variation for All Days Sampled During the Baseline Period (2000-2004) ............................33 Figure 3.1- 3. Yellowstone IMPROVE Site

- Pollutant Species Variation for All Days Sampled in 2004 .....................................................................................................34 Figure 3.1- 4. Yellowstone IMPROVE Site - Baseline Worst Day Aerosol Composition Compared to Visibility Improvement Needed by 2018 & 2064 .............................34 Figure 3.2-1. North Absaroka IMPROVE Site - Average Pollutant Species Contribution to 20% Best and 20% Worst Days Baseline (2000-2004) ................................ ..........35 Figure 3.2-2. North Absaroka IMPROVE Site - Monthl y Average Pollutant Species Variation for All Days Sampled During th e Baseline Period (2000-2004) ............36 Figure 3.2-3. North Absaroka IMPROVE Site - Pollutant Species Variation for All Days Sampled in 2004 .....................................................................................................36 Figu re 3.2-4. North Absaroka IMPROVE Site - Baseline Worst Day Aerosol Composition Compared to Visibility Impr ovement Needed by 2018 & 2064 .............................37 Figure 3.3-1. Bridger IMPROVE Site - Average Pollutant Species Contribution to 20% Best and 20% Worst Days Baseline (2000-2004)...................................................38 Figure 3.3-2. Bridger IMPROVE Site - Monthly Average Pollutant Species Variation for All Days Sampled During the Baseline Period (2000-2004) ..................................38vii Figure 3.3- 3. Bridger IMP ROVE Site

- Pollutant Species Variation for All Days Sampled

in 2004 ....................................................................................................................39 Figure 3.3-4. Bridger IMPROVE Site - Baseline Worst Day Aerosol Composition Compared to Visibility Improvement Needed by 2018 & 2064 .............................39 Figure 5.2.1-1. PSAT Sulfate Contribution at Yellowstone NP, Grand Teton NP, and Teton

Wilderness on 20% Worst Visibility Days ...........................................................55 Figure 5.2.1-2. PSAT Sulfate Contribution at North Absaroka Wilderness and Washak ie Wilderness Areas on 20% Worst Visibility Days .................................................56 Figure 5.2.1-3. PSAT Sulfate Contribution at Bridger Wilderness and Fitzpatri ck Wilderness Areas on 20% Worst Visibility Days ....................................................................57 Figure 5.2.2-1. PSAT Sulfate Contribution at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Best Visibility Days .....................................................59 Figure 5.2.2-2. PSAT Sulfate Contribution at North Absaroka Wilderness and Washak ie

Wilderness Areas on 20% Best Visibility Days ...................................................60 Figure 5.2.2-3. PSAT Sulfate Contribution at Bridger Wilderness and Fitzpatri ck Wilderness Areas on 20% Best Visibility Days ......................................................................61 Figure 5.2.3-1. PSAT Nitrate Contribution at Yellowstone NP, Grand Teton NP, and T eton Wilderness Area on 20% Worst Visibility Days ..................................................62 Figure 5.2.3-2. PSAT Nitrate Contribution at North Absaroka Wilderness and Washak ie Wilderness Areas on 20% Worst Visibility Days .................................................63 Figure 5.2.3-3. PS AT Nitrate Contribution at Bridger Wilderness and Fitzpatrick Wilderness

Are as on 20% Worst Visibility Days ....................................................................64 Figure 5.2.4-1. PSAT Nitrate Contribution at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Best Visibility Days .....................................................65 Figure 5.2.4-2. PSAT Nitrate Contribution at North Absaroka Wilderness and Washak ie Wilderness Areas on 20% Best Visibility Days ...................................................66 Figure 5.2.4-3. PSAT Nitrate Contribution at Bridger Wild erness and Fitzpatrick Wilderness Areas on 20% Best Visibility Days ......................................................................67 Figure 5.2.5-1. WEP Potential Contribution to OC at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Worst Visibility Days .......................................68 Figure 5.2.5-2. WEP Potential Contribution to OC at North Absaroka Wilderness and

Washakie Wilderness Areas on 20% Worst Visibility Days ...............................69 Figure 5.2.5-3. WEP Potential Contribution to OC at Bridger Wilderness and Fitz patrick

Wilderness Areas on 20% Worst Visibility Days ................................................69 Figure 5.2.6-1. WEP Potential Contribution to OC at Yellowstone NP, Grand Teton NP, and

Teton Wilderness Area on 20% Best Visibility Days ..........................................70 Figur e 5.2.6-2. WEP Potential Contribution to OC at North Absaroka Wilderness and

Washakie Wilderness Area s on 20% Best Visibility Days ..................................71 Figure 5.2.6-3. WEP Potential Contribution to OC at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Best Visibility Days ..................................................71 Figure 5.2.7-1. WEP Potential Contribution to EC at Yellowstone NP, Grand Teton NP, and

Teton Wilderness Area on 20% Worst Visibility Days .......................................72 Figure 5.2.7-2. WEP Potential Contribution to EC at North Absaroka Wilderness and

Washakie Wilderness Areas on 20% Worst Visibility Days ...............................73 Figure 5.2.7-3. WEP Potential Contribution to EC at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Worst Visibility Days ................................................73viii Figure 5.2.8-1. WEP Potential Contribution to EC at Yellowstone NP, Grand Teton NP, and

Teton Wilderness Area on 20% Best Visibility Days ..........................................74 Figure 5.2.8-2. WEP Potential Contribution to EC at North Absaroka Wilderness and

Washakie Wilderness Area s on 20% Best Visibility Days ..................................75 Figure 5.2.8-3. WEP Potential Contribution to EC at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Best Visibility Days ..................................................75 Figure 5.2.9-1. WEP Potential Contribution to Fine PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Worst Visibility Days .........................76 Figure 5.2.9-2. WEP Potential Contribution to Fine PM at North Absaroka Wilderness and

Washakie Wilderness Areas on 20% Worst Visibility Days ...............................77 Figure 5.2.9-3. WEP Potential Contribution to Fine PM at Bridger Wilderness and Fitzpatrick Wildernes s Areas on 20% Worst visibility Days ..............................77 Figure 5.2.10-1. WEP Potential Contribution to Fine PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Best Visibility Days ..........................78 Figure 5.2.10-2. WEP Potential Contribution to Fine PM at North Absaroka Wilderness and

Washakie Wilderness Area s on 20% Best Visibility Days ................................79 Figure 5.2.10-3. WEP Potential Contribution to Fine PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Best Visibility Days ..............................79 Figure 5.2.11-1. WEP Potential Contribution to Coarse PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Worst Visibility Days .......................80 Figure 5.2.11-2. WEP Potential Contribution to Coarse PM at North Absaroka Wilderness

and Washakie Wilderness Areas on 20% Worst Visibility Days ......................81 Figure 5.2.11-3. WEP Potential Contribution to Coarse PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Worst Visibility Days ...........................81 Figure 5.2.12-1. WEP Potential Contribution to Coarse PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Best Visibility Days ..........................82 Figure 5.2.12-2. WEP Potential Contribution to Coarse PM at North Absaroka Wilderness

and Washakie Wilderness Are a s on 20% Best Visibility Days .........................83 Figure 5.2.12-3. WEP Potential Contribution to Coarse PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Best Visibility Days ..............................84 Figure 5.3.1-1. Glide Slope by Pollutant on 20% Worst Days for Yellowstone NP, Grand Teton NP, and Teton Wilderness Area .....................................................86 Figure 5.3.1-2. Glide Slope by Pollutant on 20% Worst Days for North Absaroka and

Washakie Wilderness Areas ................................................................................87 Figure 5.3.1-3. Glide Slope by Pollutant on 20% Worst Days for Bridger and Fitzpatrick

Wilderness Areas .................................................................................................88 Figure 6 .5.8-1. Additional Cumulative NO

x Reductions From Wyoming BART Sources ........112 Figure 7.6-1. Time Series Plot by Pollutant on 20% Worst Days for Yellowstone NP, Grand Teton NP, and Teton Wilderness Area ......................................................130 Figure 7.6- 2. Time Series Plo t by Pollutant on 20% Worst Days for North Absaroka

Wilderness and Washakie Wilderness Areas ........................................................131 Figure 7.6-3. Time Series Plot by Pollutant on 20% Worst Days for Bridger and Fitzpatrick

Wilderness Areas ..................................................................................................131

F i gure 8 .1.2.1-1. Wyoming, South Dakota, Montana, Idaho, Utah, Colorado and North

Dakota Class I Areas .......................................................................................133 Figure 8.3.6-7. Additional Cumulative NO

x Red uctions From Wyoming Sources....................177ix Fi gure 9 -1. Links to Site Locations a nd Monitors ......................................................................179 Figure 11 .1-1. Regional Planning Organizations ........................................................................185 Figure 13 .5.1-1. Schematic of the IMPROVE Sampler Showing the Four Modules

Wi th Separate Inlets and Pumps .......................................................................1941 

### CHAPTER 1

GENERAL PLAN PROVISIONS

Section 169A of the Clean Air Act establishes a national goal for protecting visibility in Federally

- protected scenic areas. These Class I areas include national parks and wilderness areas. Regional haze is a type of visibility impairment caused by air pollutants emitted by numerous sources across a broad region. On July 1, 1999, the Environmental Protection Agency (EPA) issued regional haze rules to comply with requirements of the Clean Air Act. Under 40 CFR 51.308, the rule requires the State of Wyoming to develop State Implementation P lans (SIPs) which include visibility progress goals for each of the seven Class I areas in Wyoming , as well as emission reduction strategies and other measures to meet these goals. Under 40 CFR 51.309, the rule also provided an optional approach to Wyoming and eight other western states to incorporate emission reduction strategies issued by the Grand Canyon Visibility Transport Commission (GCVTC) designed primarily to improve visibility in 16 Class I areas on the

Colorado Plateau.

On December 29, 2003, the State of Wyoming submitted a visibility SIP to meet the requirements of 40 CFR 51.309. The 2003 309 SIP and subsequent revisions to the 309 SIP address the first phase of requirements, with an emphasis on stationary source SO 2 emi ssion reductions and a focus on improving visibility on the Colorado Plateau. In the 2003 submittal, Wyoming committed to addressing the next phase of visibility requirements and additional visibility improvement in Wyomi ng’s seven Class I areas by means of a State Implementation Plan meeting the requirements in 309(g).

Since the 2003 submittal of the 309 SIP, EPA has revised both 40 CFR 51.308 and 309 in response to numerous judicial challenges. As a result of revisions to the Federal rules, the State

o f Wyoming submitted revisions to the December 29, 2003, 309 SIP under separate cover, on November 21, 2008.

This 309(g) SIP submission serves as a supplement to the 309 SIP submittal. Pursuant to the requirements of 51.309(g), the State of Wyoming submits thi s P lan with: a demonstration of expected visibility conditions for the most impaired and least impaired days at the additional mandatory Class I areas; provisions for establishing reasonable progress goals for Wyoming’s seven Class I areas complying with 51.308(d)(1)-(4); long-term strategies that build upon emission reduction strategies developed in the first 309 SIP submittal; and finally provisions to address long- term strategies and Best Available Retrofit Technology (BART) requirements for

statio nary source Particulate Matter (PM) and Nitrogen Oxide (NO

x ) emissions pursuant to 51.308(e).

The State of Wyoming commits to participate in a Regional Planning Process with Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, and Washington, and commits to continue participation through future SIPs. The Regional Pl anning Process describes the process, goals, objectives, management and decision making structure, deadlines for completing significant technical analyses and developing emission management strategies and a regulation implementing the recommendations of the regional group. All Western Regional Air Partnership (WRAP) Work Plans and the WRAP2 2008-2012 Strategic Plan, which document the Regio nal Planning Process, are contained in Chapter 1 of the Wyoming Technical Support Document (TSD).

Pursuant to the Tribal Authority Rule, any Tribe whose lands are surrounded by the State of Wyoming have the option to develop a regional haze TIP for their lands to assure reasonable progress in the seven Class I areas in Wyoming. As such, no provisions of this Implementation Plan shall be construed as being applicable to Indian Country.3 

### CHAPTER 2

WYOMING CLASS I AREAS; BASELINE, NATURAL AND

CURRENT VISIBI LITY CONDITIONS

2.1 Description of the Yellowstone Monitoring Site (YELL2) Class I Areas

The monitoring site designated as “YELL2” is the representative regional haze monitoring station for three Wyoming Class I areas (Grand Teton National Park, Ye llows tone National Park

and Teton Wilderness). Each of these Class I areas are described below.

Figure 2 .1

- 1. National Parks and Wilderness Areas in Wyoming (Cl ass I Areas) ( http://www.coha.dri.edu/web/state_analysis/Wyoming/Wyoming.html )

2.1.1 Grand Teton National Park

Figure 2 .1.1 -1 . Mormon Row (Courtesy of National Park Service)4 Grand Teton National Park occupies 309,995 acres along the Teton Range and adjacent Jackson

L ake. The Teton Range borders the west side of the National Park, with elevations exceeding 12,000 feet, and 13,770 feet at the summit of the Grand Teton. The Teton Range, a 40- mile

- long mountain front, was formed from earthquakes that occurred over the p ast 13 million years along

a fault line. The eastern half of the Park consists of Jackson Lake and valley of the upper Snake River. Where the Snake River exits the Park at the south boundary, the elevation is the lowest at 6,800 feet. The Park is adjacent to the Teton Wilderness to the northeast and is 6 miles south of

Yellowstone National Park and the headwaters of the Snake River (Figure 2 .1-1) . Seven glacial

lakes li e at the base of the range, while over 100 alpine lakes can be found in the backcount ry. Elk, moose, mule deer, bison, pronghorn and black bears can be found in the Park. Grizzlies can also be found, but are located in more remote areas. Over 300 species of birds, including bald eagles, peregrine falcons and trumpeter swans can be observed in the Park.

Figure 2 .1.1 -2 . Grand Teton NP Class I Boundary ( http://www.coha.dri.edu/images/clipart/wy_20km_terrain_grandteton.jpg )5 2.1.2 Teton Wilderness

Fi gure 2 .1.2 -1 . Gravel Creek in 1996. Burned in giant Huck Fire of 1988. (Courtesy of Ralph Maughan) ( http://www.forwolves.org/ralph/wpages/tetonwld.htm )

Figure 2 .1.2 -2 . Pendergraft Peak 1991 (Courtesy of U.S. Forest Service) ( http://www.fsvisimages.com/gallery/TETO/start.htm )

The Teton Wilderness encompasses 585,468 acres which straddle the Continental Divide in western Wyoming. It is bordered by Yellowstone National Park to the north, Grand Teton National Park to the west, and the Washakie Wilderness to the east (Figure 2 .1-1). Elevations6 range from 7,500 to 9,675 feet west of the Continental Divide, while east of the Continental Divide elevations are generally higher with the summit of Younts Peak reaching 12,165 feet. At

T wo Ocean Pass, Two Ocean Creek stradd les the Continental Divide, sending waters to both the

Atlantic and the Pacific Oceans . As with Grand Teton National Park, elk, moose, mule deer, bison, pronghorn and black bears can be found in the Teton Wilderness. Bighorn sheep, mountain lions, wolves, grizzlies and a t least 75 other mammal species are also found here, as well as over 300 species of birds and 30 species of fish.

Figure 2 .1.2 -3. Teton Wilderness Class I Boundary ( http://www.coha.dri.edu/images/clipart/wy_20km_terrain_teton.jpg )7 2.1.3 Yellowstone National Park

Figure 2 .1.3 -1 . Hot Pool Near Red Cone Geyser (Courtesy National Park Service) ( http://www.nps.gov/archive/yell/slidefile/thermalfeatures/hotspringsterraces/others/Images/06202.jpg )

Yellowstone National Park became the world’s first national park on March 1, 1872, and

occup ies 2,221,766 acres in northwestern Wyoming, overlapping into Montana and Idaho (Figure 2 .1-1). The highest elevation is 11,358 feet at the summit of Eagle Peak on the southeastern Park boundary, while the lowest elevations (5,314 feet) are found where th e Yellowstone River exits the Park on the north boundary. Yellowstone Lake is the largest high

altitude lake in North America and is centered over the Yellowstone Caldera , the largest supervolcano on the continent. The caldera, considered an active volcano, has erupted several times in the last two million years. Fifty percent of the world ’ s geothermal features are in Yellowstone, fueled by this ongoing volcanic activity. Wildlife abounds in the Park, with the more common species being elk, bison, grizzlies and wolves. In 2007, approximately 3,151,373 people visited Yellowstone National Park, bringing the total number of visitors to over 142,681,000 since the park opened in 1872.8 Figure 2 .1.3 -2 . Yellowstone National Park Boundary (Courtesy of Nation al Park Service) ( http://www.nps.gov/carto/PDF/YELLmap2.pdf )

2.1.4 Monitoring Strategy and Location - YELL2 Monitoring Site

The IMPROVE site designated as the monitor representing Grand Teton National Park , Teton

Wilderness and Yellowstone National Park is YELL2. The Wyoming Department of Environmental Quality, Air Quality Division (the Division), considers the YELL2 site as adequate for assessing reasonable progress goals of the three above

- mentioned Class I areas and no additional monitoring sites or equipment are necessary at this time.

The Air Quality Division routinely participates in the IMPROVE monitoring program by attending Western States Air Resources Council (WESTAR) and Western Region al Air Partnership (WRAP) meetings and maintaining memberships in both organizations.9 YELL2 is located in central Yellowstone National Park near the north shore of Yellowstone

Lake. It is 37 miles north of Grand Teton National Park, across the Continenta l headwaters

divide between the Yellowstone River and Snake River watersheds. YELL2 is 30 miles north and west of the nearest Teton Wilderness boundary

. The YELL2 site elevation is 7,954 feet,

which is 220 feet above Yellowstone Lake.

The nearest metrop olitan area to the YELL2 monitor, Billings, Montana (over 149,650 population), is situated approximately 124 miles northeast of the monitor . The metropolitan area of Boise, Idaho (over 635,450 population) lies approximately 295 miles to the south west of the monitor and the metropolitan area of Salt Lake City, Utah (over 1,099,000) is located approximately 273 miles to the southwest.

Figure 2 .1.4 -1 . YELL2 Monitoring Site Location ( http://www.coha.dri.edu/images/clipart/wy_20km_terrain_yellowstone.jpg ) YELL2

Yellowstone Lak e10 Figure 2 .1.4 -2 . Looking South Toward the YELL2 Monitor ( http://vista.cira.colostate.edu/views/Web/SiteBrowser/SiteBrowser.aspx )

2.1.5 Assessment of Baseline, Natural and Current Conditions
- YELL2 Class I Areas

Natural visibility represents the visibility condition that w ould be experienced in the absence of

human- caused impairment. Based on EPA guidance, Grand Teton National Park, Teton

Wilderness and Yellowstone National Park Class I areas have a n established natural visibility of

0.43 deciviews for the 20 percent best days and 6.44 deciviews for the 20 percent worst days.

This is based on on- site data at the YELL2 IMPROVE monitor ing site.

Baseline visibility is determined from the YELL2 monitoring site (located in central Yellowstone Park) for the 20 percent best an d 20 percent worst days for the years 2000 through 2004 as specified in the Regional Haze regulations under 40 CFR 51.308(d)(2)(i). The baseline visibility

for Grand Teton National Park, Teton Wilderness and Yellowstone Nat ional Park Class I areas is

2.58 deciviews for the 20 percent best days and 11.76 deciviews for the 20 percent worst days, which, for this first SIP submittal, is also the same as the c urrent visibility . These best and worst 20 percent conditions are also calculated based on EPA guidanc e. This technical information was obtained from the “Haze Planning” section of the Western Regional Air Partnership (WRAP) Technical Support System (TSS) by choosing the “Monitoring” section followed by the “Deciview Glide Slope” information at http://vista.cira.colostate.edu/tss/ . Further description of

this technical info rmation can be found in Chapter 13.

Photographs representing similar visibility conditions on best and worst days for baseline and

natu ral conditions are included in F igures 2.1.5-1 through 2.1.5-4.11 Figure 2 .1.5 -1 . YELL2 Monitor
- Baseline Best Days

htt p://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/YELL/start.htm

Figure 2 .1.5 -2 . YELL2 Monitor
- Baseline Worst Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/YELL/start.htm 

### Baseline Best Days

Vista Reference: Avalanche P eak (Yellowstone National Park)

Photo Taken at 9:00 AM

Haze Index (HI) = 3 Deciviews

B ext = 14 Mm -1

Visual Range = 280 km/174 mi



### Baseline Worst Days

Vista Reference: Avalanche P eak (Yellowst one National Park)

Photo Taken at 9:00 AM

Haze Index (HI) = 12 Deciviews

B ext = 33 Mm -1

Visual Range = 120 km/75 mi12 Figure 2 .1.5 -3. YELL2 Monitor
- Natural Best Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/YELL/start.htm

Figure 2 .1.5 -4. YELL2 Monitor
- Natural Worst Days

ht tp://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/YELL/start.htm 

### Natural Best Days

Vista Reference: Avalanche P eak (Yellowstone National Park)

Photo Taken at 9:00 AM

Haze Index (HI) = 0 Deciview

B ext = 10 Mm -1

Visual Range = 390 km/242 mi



### Natural Worst Days

Vista Reference: Avalanche P eak (Yellowstone National Park)

Photo Taken at 9:00 AM

Haze Index (HI) = 6 Deciviews

B ext = 18 Mm -1

Visual Range = 220 km/137 mi13 2.2 Description of the North Absaroka Monitoring Site (NOAB1) Class I Areas

The monitoring site designated as “NOAB1” is the representative regional haze monitoring

stat ion for two Wyoming Class I areas (North Absaroka Wilderness and Washakie Wilderness).

Each of these Class I areas are described below.

2.2.1 North Absaroka Wilderness

Figure 2 .2.1 -1. Pilot an d Index Peaks (Courtesy of Wikip edia and National Park Service ) ( http://commons.wikimedia.org/wiki/User:MONGO/Public_Domain_Images )

The North Absaroka Wilderness is part of the Greater Yellowstone Area of northwestern Wyoming, located along the northeastern boundary of Yellowstone National Park, east of the Continental Divide, and occupies 350,488 acres (Figure 2 .1-1). Elevations range from approximately 7,200 feet to more than 10,000 feet on several summits, with the highest elevation being 12, 216 feet on Dead Indian Peak. The terrain is very rugged and mountainous and dissected by numerous creeks. Only a few lakes exist, but the streams contain cutthroat, brown, brook, and rainbow trout. The wilderness is home to grizzly bears , and b ig

- game hunters come by the hundreds for bighorn sheep, elk, and moose. Marm ots and pikas dominate many of the talus slopes.14 Figure 2 .2.1 -2 . North Absaroka Wilderness Boundary http://www.publiclands.org/explore/quadrant_map.php?id=1560&site_name=North%20Absaroka%20Wilderness& quad=WY_Q2&PHPSESSID=23cfeb7c915 2.2.2 Washakie Wilderne ss

Figure 2 .2. 2-1 . Piney Creek With Part of Carter Moun tain at Head of Canyon ( Courtesy

of Ralph Maughan) ( http://www.forwolves.org/ralph/wpages/washakie.htm )

The Washakie Wilderness Area encompasses 704,529 acres around the headwaters of the South Fork of the Shoshone River in northwestern Wyoming. It is bordered on the w est by the Teton Wilderness and Yellowstone National Park, and the North Absaroka Wilderness Area lies to the

north across the North Fork of the Shoshone River (Figure 2 .1-1 ). Elevations range from approximately 6,000 feet to 13,153 feet (Francs Peak) on the eastern boundary. Terrain is rugged and difficult to maneuver in many areas of this wilderness. Wildlife is bountiful, with mule deer, white-tailed deer, moose, elk, grizzly and black bear, pronghorns and bighorn sheep being some of the more common s pecies. This area has fewer lakes than some of the other areas

, so fishing opportunities are more limited. However, there are several streams and rivers which do support trout.16 Figure 2 .2. 2-2 . Washakie Wilderness Class I Area Boundary ( http://www.coha.dri.edu/images/clipart/wy_20km_terrain_washakie.jpg )

2.2.3 Monitoring Strategy and Location - NOAB1 Monitoring Site

The IMPROVE site designated as the monitor representing the North Absaroka and Washakie

Wilderness Areas is NOAB1

. Collection of data at the NOAB1 monitoring site is subsidized by the Wyoming Department of Environmental Quality. The Division considers the NOAB1 site as adequate for assessing reasonable progress goals of the two above- mentioned Class I areas and no additional monitoring sites or equipment are necessary at this time.

The Air Quality Division routinely participates in the IMPROVE monitoring program by attending Western States Air Resources Council (WESTAR) and Western Regional Air Partnership (WRAP) meetings and maintaining memberships in both organizations.

NOAB1 is located in Dead Indian Pass, approximately 25 miles northwest of Cody, Wyoming and about 3 miles northeast of the closest North Absaroka Wilderness Area boundary. It is 25 miles north of the Washakie Wilderness boundary. The NOAB1 monitoring site elevation is 8,134 feet, which is 538 feet below the summit of Dead Indian Hill to the northeast and 66 feet above Dead Indian Pass and State Highway SR 296.

The nearest metropolitan area to the NOAB1 monitor, Billings, Montana (over 149,650 population), is situated approximately 83 miles northeast of the monitor. The metropolitan area of Boise, Idaho (over 635,450 population) lies approximately 348 miles to the south west of the17 monitor and the metropolitan area of Salt Lake City, Utah (over 1,099,000) is located approximately 3 01 miles to the southwest.

Figure 2 .2.3 -1. NOAB1 Monitoring Site http://www.coha.dri.edu/images/clipart/wy_20km_terrain_northabsaroka.jpg18 Figure 2 .2.3 -2 . Looking South Toward the NOAB1 Monitor ( http://vista.cira.colostate.edu/views/Web/SiteBrowser/SiteBrowser.aspx )

2.2.4 Assessment of Baseline, Natural and Current Conditions
- NOAB1 Class I Are as

Natural visibility represents the visibility condition that would be experienced in the absence of human-caused impairment. Based on EPA guidance, the North Absaroka Wilderness and

Washakie Wilderness Class I areas have an established natural visibil ity of 0.58 deciviews for the 20 percent best days and 6.83 deciviews for the 20 percent worst days. This is based on onsite data at th e NOAB1 IMPROVE monitoring site.

Baseline visibility is determined from the NOAB1 monitoring site (located in Dead In dian Pass, about 25 miles northwest of Cody, Wyoming) for the 20 percent best and 20 percent worst days for the years 2002 through 2004 as specified in the Regional Haze regulations under 40 CFR 51.308(d)(2)(i). The baseline visibility for the North Absaroka and Washakie Wilderness Class I

areas is 2.02 deciv iews for the 20 percent best days and 11.45 deciviews for the 20 percent worst days, which, for this first SIP submittal, is also the same as the c urrent visibility . These best and worst 20 percent co nditions are also calculated based on EPA guidance. This technical information was obtained from the “Haze Planning” section of the Western Regional Air Partnership (WRAP) Technical Support System (TSS) by choosing the “Monitoring” section followed by the “Deciview Glide Slope” information at http://vista.cira.colostate.edu/tss/

. Further description of this technical information can be found in Chapter 13

.

The historic visibility photo record is limite d and does not include the North Absaroka or Washakie Wilderness areas. Photos depicting similar visibility scenarios from the Bridger Wilderness (Mt. Bonneville) have been substituted as F igures 2.2.4-1 through 2.2.4-4 for the

baseline and natural condit ions on the best and worst days.19 Figure 2 .2.4 -1 . BRID1 Monitor
- Baseline Best Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm

Figure 2 .2.4 -2 . BRID1 Monitor
- Baseline Worst Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm 

### Baseline Best Days

Vista R eference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9:00 AM

Haze Index (HI) = 2 Deciviews

B ext = 12 Mm -1

Visual Range = 330 km/205 mi



### Baseline Worst Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9:00 AM

Haze In dex (HI) = 11 Deciviews

B ext = 30 Mm -1

Visual Range = 130 km/81 mi20 Figure 2 .2.4

- 3. BRID1 Monitor
- Natural Best Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm

Figure 2 .2.4 -4 . BRID1 Monitor
- Natural Worst Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/star t.htm 

### Natural Best Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9:00 AM

Haze Index (HI) = 1 Deciview

B ext = 11 Mm -1

Visual Range = 350 km/217 mi



### Natural Wors t Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9:00 AM

Haze Index (HI) = 7 Deciviews

B ext = 20 Mm -1

Visual Range = 200 km/124 mi21 2.3 Description of the Bridger Monitoring Site (BRID1) Class I Areas

The monitoring site designated as “BRID1” is the representative regional haze monitoring station for two Wyoming Class I areas (Bridger Wilderness and Fitzpatrick Wilderness) . Each of these

Class I areas are described below.

2.3.1 Bridger Wilderness

Figure 2 .3.1 -1 . Slide Lake (Photo Courtesy of Ralph Maughan) ( http://www.forwolves.org/ralph/wpages/bridger.htm )

The Bridger Wilderness, consisting of 428,169 acres, is situated on the west slope of the Wind River Range in Wyoming and extends approximately 80 m iles along the western slope of the

Continental Divide. The wilderness lies south of the other six Class I areas and is on the west border of the Fitzpatrick Wilderness (Figure 2.1-1 ). The Bridger Wilderness is a combination of jagged granite rock, alpin e forest and open alpine meadows and is the headwaters for the Green River. This wilderness forms a triple divide for three major watersheds: the Columbia River, the Colorado River, and the Missouri River. The Wind River Range contains numerous peaks, s ome exceeding 13,000 feet, the highest of which is Gannett Peak (13,804 feet) located on the boundary between the Bridger Wilderness and the adjacent Fitzpatrick Wilderness to the east. This wilderness contains seven of the ten largest glaciers in the U.S. (lower 48). Some of the more common species found in the Bridger Wilderness are mule deer, moose, elk, bighorn sheep, gray wolf, and both grizzly and black bear.22 Figure 2 .3.1 -2 . Bri dger Wilderness Monitoring Site and Partial Boundary http://www.coha.dri.edu/images/clipart/wy_20km_terrain_bridger.jpg

Figure 2 .3.1 -3 . Bridger Wilderness Boundary http://www.publiclands.org/explore/quadrant_map.php?id=1742&site_name=Bridger%20Wilderness&quad=WY_Q

823 2.3.2 Fitzpatrick Wilderness

Figure 2 .3. 2-1 . The Wind Rivers From the Wind River Indian Reservation (Courtesy of Ralph Maughan) http://www.forwolves.org/ralph/wpages/graphics/fitzpatrick1.jpg

The Fitzpatrick Wilderness Area (191,103 acres) is located on the east slope of the northern Wind River Range in Wyoming along the Continental Divide, which makes up its western border. It shares its western border with the Bridger Wilderness Area, while its eastern border is shared with the Wind River Indian Reservation. Elevations range from approximately 5,575 feet

at the weste rn side of the upper Wind River Basin at river level to east slope elevations of 8,200 feet. Gannett Peak claims the highest elevation (13,804 feet) and is on the Divide boundary between the Fitzpatrick Wilderness and the adjacent Bridger Wilderness to th e east. Precipitous canyons formed by glaciers from granite and limestone rock are found throughout the area. Alpine meadows, stands of timber and rocky plateaus are also common sights. There are more than 60 lakes and at least 75 miles of streams which tout excellent trout fishing. Abundant

wildlife include s elk, mule deer, moose, bighorn sheep, black bear, bobcats and coyotes.24 Figure 2 .3. 2-2 . Fitzpatrick Wilderness Class I Boundary http://www.coha.dri.edu/images/clipart/wy_20km_terrain_fitzpatrick.jpg

2.3.3 Monitoring Strategy and Location - BRID1 Moni toring Site

The IMPROVE site designated as the monitor representing the Bridger and Fitzpatrick

Wilderness Areas is BRID 1. The Division considers the BRID 1 site as adequate for assessing reasonable progress goals of the two above- mentioned Class I areas and no additional monitoring sites or equipment are necessary at this time.

The Air Quality Division routinely participates in the IMPROVE monitoring program by attending Western States Air Resources Council (WESTAR) and Western Regional Air Partnership (WRAP) meetings and maintaining memberships in both organizations.

BRID1 is located at the White Pine Ski Area, 10 miles northeast of Pinedale, Wyoming and approximately 2 miles outside of the southwestern Bridger Wilderness boundary. The monitoring site sits on a small hilltop in a high basin on the west slope of the Wind River Range at an elevation of 8,553 feet. The site is approximately 1,148 feet above Fremont Lake which lies slightly over 1 mile to the west, and about the same distance below the ele vation of the nearest Bridger Wilderness boundary to the northeast. BRID1 is approximately 1,378 feet higher than the upper Green River Basin town of Pinedale.

The nearest metropolitan area to the BRID1 monitor, Salt Lake City, Utah (over 1,099,000), is located approximately 187 miles to the southwest. The metropolitan area of Billings, Montana (over 149,650 population), lies approximately 203 miles to the northeast of the monitor and the25 metropolitan area of Boise, Idaho (over 635,450 population), is si tuated approximately 329 miles

southwest of the monitor.

Figure 2 .3.3 -1 . BRID1 Monitoring Site http://www.coha.dri.edu/images/clipart/wy_20km_terrain_bridger.jpg

Figure 2 .3. 3-2 . Looking North Toward BRID1 Monitor http://vista.cira.colostate.edu/Images/Photos/IMPROVE/BRID1/BRID1_2005_N_IN.JPG26 2.3.4 Assessment of Baseline, Natural and Current Conditions
- BRID1 Class I Areas

Natural visibility represents the visibility condition that would be experienced in the absence of human-caused impairment. Based on EPA guidance, t he Bridger and Fitzpatrick Wilderness

Class I areas have an es tablished natural visibility of 0.28 deciviews for the 20 percent best days

and 6.45 deciviews for the 20 percent worst days. This is based on on- site data at the BRID 1

IMPROVE monitor ing site.

Baseline visibility is determined from the BRID1 monitoring site (located at the White Pine Ski Area, 10 miles northeast of Pinedale, Wyoming) for the 20 percent best and 20 percent worst days for the years 2000 through 2004 as specified in the Regional Haze regulations under 40 CFR 51.308(d)(2)(i). The baseline visibility for t he Bridger and Fitzpatrick Wilderness Class I

areas is 2.1 deciv iews for the 20 percent best days and 11.12 deciviews for the 20 percent worst days, which, for this first SIP submittal, is also the same as the c urrent visibility . These be st and worst 20 percent conditions are also calculated based on EPA guidance. This technical information was obtained from the “Haze Planning” section of the Western Regional Air Partnership (WRAP) Technical Support System (TSS) by choosing the “Monitorin g” section followed by the “Deciview Glide Slope” information at http://vista.cira.colostate.edu/tss/

. Further description of this technical information can be found in Chapter 13

.

Photographs represen ting similar visibility conditions on best and worst days for baseline and

natural conditions are included in F igures 2 .3.4-1 through 2.3.4-4.27 Figu re 2 .3.4 -1 . BRID1 Monitor
- Baseline Best Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm

Figure 2 .3.4 -2 . BRID1 Monitor
- Baseline Worst Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm 

### Baseline Best Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9: 00 AM

Haze Index (HI) = 2 Deciviews

B ext = 12 Mm -1

Visual Range = 330 km/205 mi



### Baseline Worst Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9:00 AM

Haze Index (HI) = 11 Deciviews

B ext = 30 Mm -1

Visual Range = 130 km/81 mi28 Figure 2 .3.4 -3 . BRID1 Monitor
- Natural Best Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm

Figure 2 .3.4 -4 . BRID1 Monitor
- Natural Worst Days http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm 

### Natural Best Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Photo Taken at 9:00 AM

Haze Index (HI) = 1 Deciview

B ext = 11 Mm -1

Visual Range = 350 km/217 mi



### Natural Worst Days

Vista Reference: Mt. Bonneville (Bridger Wilderness)

Ph oto Taken at 3:00 PM

Haze Index (HI) = 6 Deciviews

B ext = 18 Mm -1

Visual Range = 220 km/137 mi29 

### CHAPTER 3

POLLUTANTS CAUSING VISIBILITY IMPAIRMENT

IN WYOMING CLASS I AREAS

This chapter provides a summary of regional haze monitoring data from the IMPROVE monitoring sites in Wyoming, and the pollutants that affect visibility impairment in each of Wyoming’s Class I areas. A summary of the visibility improvement needed from baseline (2000-2004) to the 2018 unifo rm rate of progress (URP) milestone, and to the 2064 natural condition goal is also provided. Depictions of Wyoming IMPROVE monitoring sites are provided in Chapter 2

.

The haze index ( HI ) in deciview (dv) units, as discussed in EPA’s 2003 Guidance for Tr acking Progress Under the Regional Haze R ule, is a visibility metric based on the light

- extinction coefficient that expresses incremental changes in perceived visibility

. A change in the HI of one

dv is approximately equal to a 10% c hange in extinction coefficient. The haze index is defined by :

The value of the haze index is approximately zero dv for a pristine atmo sphere . This value increases as visibility degrades.

EPA’s 2003 guidance for calculating light extinction is based on the original protocol defined by the IMPROVE program in 1988. In December 2005, the IMPROVE Steering Committee voted to adopt a revised algorithm for use by IM PROVE as an alternative to the original approach.

The revised algorithm for estimating light extinction is calcul ated as recommended for use by the IMPROVE steering committee using the following equations:

b ext ≈ 2.2 x f

s (RH) x [Small Amm. Sulfate] + 4.8 x f L (RH) x [Large Amm. Sulfate]

+ 2.4 x f

s (RH) x [Small Amm. Nitrate] + 5.1 x f L (RH) x [Large Amm. Nitrat e] + 2.8 x [Small POM] + 6.1 x [Large POM] + 10 x [EC] + 1 x [Soil]

+ 1.7 x f

ss (RH) x [Sea Salt] + 0.6 x [CM] + 0.33 x [NO 2 (ppb)] + Rayleigh Scattering (Site Specific)

The revised algorithm splits ammonium sulfate, ammonium nitrate, and POM concentrations into small and large size fractions as follows:30 Chapter 13 provides additional information on light extinction.

The following table identifies the different pollutant species that contribute to haze, and their abbreviations, as they appear in the figures in this section. References to sulfate and nitrate in this section are intended to reflect ammonium sulfate and ammonium nitrate, respectively.

Table 3-1 . IMPROV E Monitor Aerosol Composition

Pollutant IMPROVE Abbreviation

Ammonium Nitrate ammno3f_bext

Ammonium Sulfate ammso4f_bext

EC (Elemental Carbon) ecf_bext

OMC (Organic Mass Carbon) omcf_bext

CM (Coarse Mass) cm_bext

Soil (Fine Soil) soilf_bext

S ea Salt seasalt_bext

The figu res which follow in this chapter provide information for each Class I area (based on representative IMPROVE monitoring site) for the 20% best and 20% worst days during the baseline period, monthly averages of all monitored days, and the improvement needed by 2018

and 2064.

Figures 3-1 and 3-2 summarize the distribution of pollutant spe cies in Wyoming’s Class I areas, for the current (2000-2004 baseline) 20% best and 20% worst days.31 Figure 3-1. Light Extinction by Pollut ant Species for Wyoming Class I Areas 20% Best Day s (2000-2004)32 Figure 3-2. Light Extinction by Pollutant Species for Wyoming Class I Areas 20% Worst Days (2000-2004)

As the above figures indicate, Wyoming’s Class I areas are dominated by sulfate and organic carbon on the 20% best days, and organic carbon and sulfate on the 20% worst days. On the 20% best days, sulfate is significant in all of the Class I areas. The majority of t his can be attributed to point sources. On the 20% worst days, organic carbon is the most significant species in all of the Class I areas , with natural fire having the largest contribution.

The following sections provide an additional breakdown of the po llutant species that contribute

to each Class I area. The first figure in each section shows a simple pie chart of the 20% best and 20% worst days, similar to the bar chart figures above. The second figure in each section shows the pollutant species based on monthly averages for all days (including best or worst) during the baseline period, as an example of the seasonal variation in Class I areas. The third figure in each section presents a closer look at the daily variation during a given year

-- in this case 2004. The fourth figure in each section shows the improvement needed (shown in reduction in deciview) for each Class I area, from the baseline year to the 2018 milestone, and to 2064

natural conditions.

3.1 Yellowstone National Park, Grand Teton Na tional Park and Teton Wilderness

As depicted in the following figures, on the best 20% days sulfate is the dominant species, but organic carbon is the largest contributor on the worst 20% days. Both sulfate and nitrate33 pollutant species fluctuate during the year. Significant spikes of organic carbon, however, are evident especially in the warmer months

, most likely due to wildfire activity. Figure 3.1-4,

indicates a 1.3 deciview reduction would be n eeded to meet a 2018 URP, and a 5.4 deciview

reduction would be needed to meet a 2064 URP . While 51.308(d)(1)(i)(B) requires that the State disclose the incremental change required to meet a URP goal, there is no requirement to meet a URP goal. This is discussed in more detail in Chapter 7.

Figure 3.1-1. Ye llowstone IMPROVE Site
- Average Pollut ant Species Contrib ution to

20% Best and 20% Worst Days Baseline (2000-2004)

( http://vista.cira.colost ate.edu/dev/web/AnnualSummaryDev/Composition.aspx )

Figure 3.1-2 . Yellowstone IMPROVE Site
- Monthly Average Pollutant Species Variation

for All Days Sampled During the Baseline Period (2000-2004)

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )34 Figure 3.1-3 . Yellowstone IMPROVE Site
- Pollutant Species Variation for All Days Sampled in 2004

(WRAP TSS

- http://vista.cira.colostate.e du/tss/ )

Figure 3.1-4. Yellowstone IMPROVE Site
- Baselin e Worst Day Aerosol Composition Compared to Visibility Improvement Needed by 2018 & 206435 3.2 North Absaroka and Washakie Wilderness Areas

As depicted in the following figures, on the best 20% days sulfate is the dominant species, but organic carbon is the largest contributor on the worst 20% days. Both sulfate and nitrate pollutant species fluctuate during the year. Like the Yellowstone IMPROVE site, the North

Absaroka IMPROVE site shows significant spikes of organic carbon, especially in the warmer months most likely due to wildfire activity. Figure 3.2-4, indicat es a 1.1 deciview reduction

would be ne eded to meet a 2018 URP, and a 4.7 deciview reduction would be needed to meet a

2064 URP . While 51.308(d)(1)(i)(B) requires that the State disclose the incremental change required to meet a URP goal, there is no requirement to meet a URP goal. This is discussed in

more detail in Chapter 7

.

Figure 3.2-1. North Absaroka IMPROVE Site
- Average Pollu tant Species Contribution to 20% Best and 20% Worst Days Baseline (2000-2004)

( http://vista.cira.colostate.edu/de v/web/AnnualSummaryDev/Composition.aspx )36 Figure 3.2-2. North Absaroka IMPROVE Site - Monthly Aver age Pollutant Species Variation for All Days Sampled During the Baseline Period (2000-2004)

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Figure 3.2-3. North Absaroka IMPROVE Site - Pollutant Species V ariation for All Days Sampled in 2004

(WRAP TSS

- http://vista.cira .colostate.edu/tss/ )37 Figure 3.2-4. North Absaroka IMPROVE Site - Baseline Worst Day Aerosol Composition Compared to Visibility Improvement Needed by 2018 & 2064

3.3 Bridger and Fitzpatrick Wilderness Areas

As with all other Wyoming Class I areas, on the best 20% days sulfate is the dominant species, but organic carbon is the largest contributor on the worst 20% days. Both sulfate and nitrate pollutant species fluctuate during the year. Like the other Class I sites, the Bridger IMPROVE site shows significant spikes of organic carbon, especially in the warmer months most likely due to wildfire activity. Figure 3.3-4, indica tes a 1.1 deciview reduction would be ne eded to meet a 2018 URP, and a 4.6 deciview reduction would be needed to meet a 2064 URP

. While 51.308(d)(1)(i)(B) requires that the State disclose the incremental change required to meet a URP goal, there is no requirement to meet a URP goal. This is discussed in more detail in Chapter 7

.38 Figure 3.3-1 . Bridger IMPROVE Site
- Average Pollutant Species Cont ribution to 20%

Best and 20% Worst Days Baseline (2000-2004)

( http://vista.cira.colos tate.edu/dev/web/AnnualSummaryDev/Composition.aspx )

Figure 3.3-2 . Bridger IMPROVE Site - Monthly Average Poll utant Species Variation for

All Days Sampled During the Baseline Period (2000 -2004)

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )39 Figure 3.3-3 . Bridger IMPROVE Site - Pollutant Species Variation fo r All Days Sampled

in 2004

(WRAP TSS

- http://vista.cira.colostate. edu/tss/ )

Figure 3.3-4 . Bridger IMPROVE Site
- Baselin e Worst Day Aerosol Composition Compared to Visibility Improvement Needed by 2018 & 206440 

### CHAPTER 4

STATEWIDE EMISSION INVENTORY

4.1 Introduction

The process for inventorying sources is similar for all species of interest. The number and types of sources is identified by various methods. For example, major stationary sources report actual annual emission rates to the EPA national emissions database. Wyoming collects annu al emission data from both major and minor sources and this information is used as input into the emissions inventory. In other cases, such as mobile sources, an EPA mobile source emissions model is used to develop emission projections. Population, employment and household data are used in other parts of the emissions modeling to characterize emissions from area sources such as home heating. Thus, for each source type, emissions are calculated based on an emission rate

and the amount of time the source i s operating. Emission rates can be based on actual measurements from the source, or EPA emission factors based on data from tests of similar types of emission sources. In essence all sources go through the same process. The number of sources

is identifi ed, emission rates are determined by measurements of those types of sources and the time of operation is determined. By multiplying the emission rate times the hours of operation in a day, a daily emission rate can be calculated. A second inventory is cr eated to predict emissions in 2018 based on expected controls, growth, or other factors. Additional inventories are created for future years to simulate the impact of different control strategies. While the Division attempts to make sound estimates of all sources of emissions in the State, they are only estimates at one point in time. Oil and gas emission estimates are some of the more complicated emission inventories that the Division collects, and the Division is working hard to improve those

estimates

.

The following presents the Wyoming emissions from the WRAP TSS.41 4.2 SO

x Emission Inventory

Table 4.2

- 1. Wyoming SO

x Emission Inventory

- 2002 and 2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inventories

Sou rce Category Statewide SO

x

Plan 02d

(tpy) PRP18b (tpy) Net Change

From Plan 02d

to PRP18b

(Percent)

Point 119,717 96,809

- 19

Area 16,689 23,093 38

On

- Road Mobile 959 81

- 92

Off

- Road Mobile 5,866 65

- 99

Oil & Gas 150 3

- 98

Road Dust 0 0 0
Fugitive Dust 0 0 0

Windblown Dust 0 0 0

Anthro Fire 173 109

- 37

Natural Fire 2,286 2,286 0
Biogenic 0 0 0

Total 145,840 122,446

- 16

Sulfur oxides (SO

x ) are compounds of sulfur and oxygen molecules. Sulfur dioxide (SO 2 ) is the predominant form found in the lower atmosphere. Sulfur dioxide emissions produce sulfate particles in the atmosphere. Ammonium sulfate particles have a significantly greater impact on visibility than other pollutants like dust from unpaved roads due to the physical characteristics

c ausing greater light scattering from the particles. Sulfur dioxide emissions come primarily from coal combustion at electrical generation facilities, but smaller amounts come from natural gas combustion, mobile sources and even wood combustion. There are natural sources of sulfur

dioxide such as volcanoes. A 16% statewide reduction in SO

x emissions is expected by 2018 due to planned controls on existing sources, even with a growth consideration in generating capacity for the State. Similar reductions are expected from other states as BART or other planned controls take effect by 2018.42 4.3 NO

x Emission Inventory

Table 4.3

- 1. Wyoming NO

x Emission Inventory

- 2002 and 2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inven tories

Source Category Statewide NO

x

Plan02d

(tpy) PRP18b (tpy) Net Change

From Plan02d

to PRP18b

(Percent)

Point 117,806 110,109

- 7

Area 15,192 19,663 29

On

- Road Mobile 38,535 9,728

- 75

Off

- Road Mobile 76,637 49,677

- 35

Oil & Gas 14,725 34,142 132

Road Dust 0 0 0
Fugitive Dust 0 0 0

Windblown Dust 0 0 0

Anthro Fire 782 484

- 38

Natural Fire 8,372 8,372 0
Biogenic 15,925 15,925 0

Total 287,974 248,100

- 14

Nitrogen oxides (NO

x ) are generated during any combustion process where nitrogen and oxygen from the atmosphere combine together under high temperature to form nitric oxide, and to a lesser degree nitrogen dioxide, and in much smaller amounts other odd oxides of nitrogen. Nitrogen oxides react in the atmosphere to form nitrate particl es. N itrogen oxide emissions in Wyoming are expected to decrease by 2018, primarily due to significant improvements in mobile

sources. It is projected that off-road and on- road vehicles emissi ons will decline by more than 55,760 tons per year from the Plan 02d emissions total of 115,172 tons per year. Point sources are also projected to decrease sta tewide emissions by about 7,700 tons per year. A power plant would be a typical example of a point source. Oil and gas development is expected to increase

statewide emissions from 2002 to 2018 by about 19,400 tons per year. With population increases and more construction, fugitive dust emissions will also increase

.43 4.4 OC Emission Inventory

Table 4.4

- 1. Wyoming OC Emission Inventory

- 2002 and 2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inventories

Source Category Statewide OC

Plan02d

(tpy) PRP18b (tpy) Net Change

From Plan02d

to PRP18b

(Percent)

Point 646 990 53

Area 2,000 1,975

- 1

On

- Road Mobile 304 249

- 18

Off

- Road M obile 625 411

- 34

Oil & Gas 0 0 0

Road Dust 20 26 30
Fugitive Dust 96 133 39

Windblown Dust 0 0 0

Anthro Fire 1,709 886

- 48

Natural Fire 23,793 23,793 0
Biogenic 0 0 0

Total 29,193 28,463

- 3

Organic carbon particles emitted directly from the comb ustion of organic materials are called primary organic aerosols. A wide variety of sources contribute to this classification including byproducts from wood and agricultural burning with emissions from natural fires as the largest contributor to organic carbon emissions. Since it is impossible to predict future emissions from natural fires, this category was held constant and organic carbon emissions from all sources are expected to show a 3% decline.44 4.5 EC Emission Inventory

Table 4.5

- 1

. Wyoming EC Emission Inventory

- 2002 and 2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inventories

Source Category Statewide EC

Plan02d

(tpy) PRP18b (tpy) Net Change

From Plan02d

to PRP18b

(Percent)

Point 104 180 73

Area 304 335 10

On

- Road Mobile 443 86

- 81

Off

- Road Mobile 1,986 1,161

- 42

Oil & Gas 0 0 0

Road Dust 2 2 0
Fugitive Dust 7 9 29

Windblown Dust 0 0 0

Anthro Fire 298 153

- 49

Natural Fire 4,922 4,922 0
Biogenic 0 0 0

Total 8,066 6,848

- 15

Elemental carbon is the carbon black, or soot, a byproduct of incomplete combustion. It is the partner to primary organic aerosols and represents the more complete combustion of fuel producing carbon particulate matter as the end product. A carbon particle has a sixteen times greater impact on visibility than that of a coarse particle of granite . Reductions in manmade

emissions in elemental carbon are largely due to mobile sources and expected new Federal emission standards for mobile sources, especially for diesel engi nes. Fleet replacement will also play a part in the reduction. Elemental carbon emissions are predic ted to decrease approximately 15% by 2018. As with organic carbon, however, the overwhelming source for elemental carbon

is from wildfires which the Divi sion cannot control or predict future emissions.45 4.6 Fine PM Emission Inventory

Table 4.6

- 1. Wyoming Fine PM Emission Inventory

- 2002 and

2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inventor ies

Source Category Statewide Fine PM

Plan02d

(tpy) PRP18b (tpy) Net Change

From

Plan02d to

PRP18b (Percent)

Point 11,375 15,709 38

Area 1,601 1,756 10

On

- Road Mobile 0 0 0

Off

- Road Mobile 0 0 0

Oil & Gas 0 0 0

Road Dust 160 206 29
Fugitive Dust 2,082 2,882 38

Windblown Dust 5,838 5,838 0

Anthro Fire 242 129

- 47

Natural Fire 1,535 1,535 0
Biogenic 0 0 0

Total 22,833 28,055 23

Fine soil emissions are largely related to agricultural and mining activities, windblown dust from construction areas and emissions from unpaved and paved roads. A particle of fine dust has a relative impact on visibility one tenth as great as a particle of elemental carbon. On any given visibility event where poor visual air quality is present in a scene, the impact of dust can vary widely. Agricultural activities, dust from unpaved roads and construction are prevalent in this source category and changes in emissions are tied to population and vehicle miles traveled. Since soil emissions are not directly from the ta ilpipe of the vehicle, the category of mobile sources does not show any emissions and all vehicle related emissions from paved and unpaved roads show up in the fugitive dust and road dust categories.46 4.7 Coarse PM Emission Inventory

Table 4 .7

- 1. Wyoming Coar se PM Emission Inventory

- 2002

and 2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inventories

Source Category Statewide Coarse PM

Plan02d

(tpy) PRP18b (tpy) Net Change

From Plan02d

to PR P18b

(Percent)

Point 24,751 30,619 24

Area 409 653 60

On

- Road Mobile 171 165

- 4

Off

- Road Mobile 0 0 0

Oil & Gas 0 0 0

Road Dust 1,125 1,449 29
Fugitive Dust 18,030 25,144 39

Windblown Dust 52,546 52,546 0

Anthro Fire 259 109

- 58

Natural Fire 5,36 9 5,369 0
Biogenic 0 0 0

Total 102,660 116,054 13

Coarse mass particles emissions are closely related to the same sources as fine soil emissions but other activities like rock crushing and processing, material transfer, open pit mining and unpaved

road emissions can be prominent sources. Coarse mass particles travel shorter distances in the atmosphere than some other smaller particles but can remain in the atmosphere sufficiently long enough to play a role in regional haze. Coarse mass particulate mat ter has the smallest direct impact on regional haze on a particle- by

- particle basis where one particle of coarse mass has a relative visibility weight of 0.6 compared to a carbon particle having a weight of 10. Increases in coarse mass are seen in the fug itive and road dust categories, as well as point and area source categories. These increases are largely attributable to population growth, vehicle miles traveled and employment data.47 4.8 Ammonia Emission Inventory

Table 4.8

- 1. Wyoming Am m onia Emission Inventory

- 2002

and 2018

Wyoming Planning and Preliminary Reasonable Progress

Emission Inventories

Source Category Statewide Ammonia

Plan02d

(tpy) PRP18b (tpy) Net Change

From

Plan02d to

PRP18b (Percent)

Point 6 85 1,398 104

Area 29,776 29,901 0

On

- Road Mobile 538 724 35

Off

- Road Mobile 41 57 39

Oil & Gas 0 0 0

Road Dust 0 0 0
Fugitive Dust 0 0 0

Windblown Dust 0 0 0

Anthro Fire 218 119

- 45

Natural Fire 1,775 1,775 0
Biogenic 0 0 0

Total 33,033 33,974 3

Ammonia emissions come from a variety of sources including wastewater treatment facilities, livestock operations, and fertilizer application and to a small extent, mobile and point sources. Increases in ammonia emissions are correlated to population statistics and increased vehicular

traffic. Ammonia is directly linked to the production of ammonium nitrate and ammonium sulfate particles in the atmosphere when sulfur dioxide and nitrogen oxides eventually convert over to these forms of particles. Mobil e source emissions are expected to rise due to increases in vehicle miles traveled. Future point source emissions are also expected to increase by 2018, however, little to no overall increases in ammonia are predicted for 2018.

4.9 Inventories Utilized For Emissions Projections

The WRAP Regional Modeling Center (RMC) developed multiple annual emissions inventories for a 2002 actual emissions base case, a planning case to represent the 2000-04 regional haze baseline period using averages for key emissions categories, and a 2018 base case of projected emissions determined using factors known at the end of 2005. All emission inventories were developed using the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system. These inventories have undergone a number of revisions throughout the development process to arrive at the final versions used in CMAQ and CAMx air quality modeli ng.

 The 2002 base case emissions scenario, referred to as “2002 Base Case” or “Base02”, represents the actual conditions i n calendar year 2002 with respect to ambient air quality and the associated sources of criteria and particulate matter air pollutants. The Base02 emissions inventories are used to validate the air quality model and associated databases48 and to demonstrate acceptable model performance with respect to replicating observed particulate matter air quality.

 The 2000-04 baseline period planning case emissions scenario is referred to as “Plan02”, and represents baseline emission patterns based on average, or “typical”, conditions. This inventory provides a basis for comparison with the future year 2018 projected emissions, as well as to gauge reasonable progress with respect to future year visibility. Plan 02d, used by the State of Wyoming in these inventories, w as last revised in October,

2008.

 The 2018 future- year base case emissions scenario, referred to as “2018 Base Case” or “Base18”, represents conditions in future year 2018 with respect to sources of criteria and particulate matter air pollutants, taking i nto consideration growth and controls. Modeling results based on this emission inventory are used to define the future year ambient air quality and visibility metrics.

 2018 Preliminary Reasonable Progress refers to a WRAP emissions or modeling scenario based on the preliminary reasonable progress emissions inve ntories, generated in early 2007. This scenario includes corrections, refinements and additions to the 2018 Base Case, as well as estimates of controlling SO 2 and some NO

x from BART sources. The

PR P18b analysis series, used by the State of Wyoming in these inventories, was last revised in August, 2009.

The CMAQ and CAMx air quality models are explained in more detail in Chapter 5.

4.10 PRP18b

A “base case” emissions projection inventory was comp iled by the WRAP in January of 2006. In June 2007, a revision to this inventory named 2018 Preliminary Reasonable Progress version “a” (PRP18a) updated the first set (base case) of projections. The most recent projections, 2018 Preliminary Reasonable Pro gress version “b” (PRP18b), provides a more current assessment of the reasonable progress toward visibility goals by the WRAP. Table 4.9-1 below depicts the net change from the PRP18a NO

x emission inventories to the PRP18b emission inventories.

Table 4.9-1. Net Change From PRP18a to PRP18b Emission Inventories

Source Category PRP18a NO

x Emission Inventory (tpy) PRP18b NO

x Emission Inventory (tpy) Net Change

From PRP18a

to PRP18b (tpy) Net Change

From PRP18a

to PRP18b (%)

Point 133,216 110,109

- 23,107

- 1 7% Area (includes Oil & Gas) 53,806 53,805 No Change No Change

On

- Road Mobile 9,728 9,728 No Change No Change

Off

- Road Mobile 59,378 49,676

- 9,702

- 16%

The off-road mobile category showed a 16% decrease in NO

x emissions, 89% of which was

attributable to locomotives. The remaining 11% was attributable to off-road equipment. A49 decrease of 17% in point source NO

x emissions was achieved, with 89% of the decrease due to BART. Area and on-road source categories remained virtually unchanged.

Three ERG Tec hnical Memorandums, documenting PRP18a and PRP18b emission inventories, can be found in Chapter 4 of the Wyoming TSD.50 

### CHAPTER 5

SOURCE APPORTIONMENT AND REGIONAL HAZE MODELING

5.1 Overview

Visibility impairment occ urs when pollutants emitted into the atmosphere scatter and absorb light, thereby creating haze. These pollutants can remain suspended in the atmosphere for long periods and be transported long distances, thereby contributing to regional- scale impacts on visibility in Class I areas. Air quality models offer the opportunity to better understand how these impacts occur, by identifying the sources that contribute to haze, and helping to select the most effective emissions reduction strategies to improve visibility.

Wyoming Class I area visibility is affected by a combination of local and regional transp ort of air pollutants. Chapter 4 provided information on emission inventories, as the first step in identifying significant source categories causing visi bil ity impairment. This chapter describes the results of (1) source apportionment analysis showing the in- state and regional contribution of

haze sources , for the 20% worst and best visibility days, and (2) regional modeling projections of visibility conditi ons by the 2018 benchmark or milestone, based on application of the regional haze strategies outlined in this Plan, including BART. The source apportionment information and regional modeling results are the basis for the demonstration of reasonable progre ss for the 20% worst and best days, described in Chapter 7.

Additional explanation of the source ap portionment and modeling methodology can be found in

the WRAP Air Quality Modeling methods document in Chapter 5 of the Wyoming TSD.

5.1.1 Source Apportio nment Analysis
- PSAT and WEP

In order to determine the significant sources contributing to haze in Wyoming ’s Class I areas, the

Division has relied upon source apportionment analysis techniques provided by the WRAP for this Regional Haze P lan. This information can be found on the WRAP TSS website at http://vista.cira.colostate.edu/TSS/Results/HazePlanning.aspx . There were two techniques used for source apportionment of regiona l haze. One was the P articulate Matter Source Apportionment Technology (PSAT) tool, used for the attribution of sulfate and nitrate sources only. The second was the Weighted Emissions Potential (WEP) tool, used for attribution of sources of sulfate, nitrate, organic carbon, elemental carbon, fine PM, and coarse PM.

PSAT uses the CAMx air quality model to show nitrate-sul fate

- ammonia chemistry and applies this chemistry to a system of tracers or “tags” to track the chemical transformatio ns, transport
and removal of NO

x and SO 2 . Emission scenarios used for the PSAT analyses were the Plan02c

and Base18b. PSAT result s were not regenerated for use in this document using the more

rece ntly updated Plan02d and PRP18b emissions scenarios because of the time and resources that would have been required. No significant changes were anticipated with additional modeling runs. These two pollutants are important because they tend to originate from anthropogenic (human-caused) sources. Therefore, the results from this analysis can be useful in determining contributing sources that may be controllable, both in- state and in neighboring

states.51 WEP is a screening tool that helps to identify source regions that have the potential to contribute to haze formation at specific Class I areas. Unlike PSAT, this method does not account for chemistry or deposition. The WEP combines emissions inventories, wind patterns, and residence time of air mass over each area where emissions occur, to estimate the percent contribution of different pollutants. Like PSAT, the WEP tool compares baseline (2000-2004) to 2018, to show the improvement expected by the 2018 URP, for sulfate, nitrate, organic carbon, elemental carbon, fine PM, and coarse PM.

As described in Section 5.2 below, the Division believes PSAT is a better tool than WEP for identifying the contribution of sulfates and nitrates to Wyoming Class I areas, because PSAT does account for chemistry and deposition, and is better at identifying regional contribution of sources from outside the WRAP region (see discussion in 5.2 below). For these reasons, the

Division has relied upon the PSAT results as the primary source apportionment tool for sulfates and nitrates, and thus the better tool for identifying anthropogenic sources. The results from the

WEP anal ysis were used by the Division primarily to identify the pollutants more commonly associated with non-anthropogenic (natural) sources. Even though these sources are mostly uncontrollable, it is still important to consider their re lative contribution to haze.

The review of PSAT result s in this chapter (discussed in 5.2 below) focus on the contribution on sulfates and nitrates, while the WEP results focus on the contribution of organic carbon, elemental carbon, fine PM, and coarse P M.

5.1.2 Regional Haze Modeling - CMAQ

The primary tool utilized by the Division for modeling regional haze improvements by 2018, and for determining Wyoming’s Reason able Progress Goals (see Chapter 7), was the Community

Multi

- Scale Air Quality (CMAQ) m odel. The CMAQ model was used to estimate 2018 visibility conditions in Wyoming and all Western Class I areas, based on application of the regional haze strategies presented in this Plan, including assumed controls on BART sources. A more in depth descri ption of the CMAQ model used to project 2018 visibil ity conditions can be

found in the WRAP Air Quality Modeling document referenced in Chapter 5 of the Wyoming

TSD.

The modeling was conducted by the Regional Modeling Center (RMC) at the University of

Cal ifornia Riverside, under the oversight of the WRAP Modeling Forum. Results can be found

on the WRAP TSS website at http://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx

.

The CMAQ model was designed as a “one atmosphere” modeling system to encompass modeling of multiple pollutants and issues, including ozone, PM, visibility, and air toxics. This is in contrast to many earlier air quality models that focused on single pol lutants. CMAQ takes into account emissions, advection and dispersion, photochemical transformation, aerosol thermodynamics and phase transfer, aqueous chemistry, and wet and dry deposition of trace species. The model requires inputs of three-dimensional gridded wind, temperature, humidity, cloud/precipitation, and boundary layer parameters. The current version of CMAQ can only utilize output fields from the MM5 meteorological model. MM5 is a state -of-the- science52 atmosphere model that has proven useful for air quality applications and has been used extensively in past local, state, regional, and national modeling efforts. MM5 has undergone extensive peer review, with all of its components continually undergoing development and scrutiny by the modeling community.

The RMC developed air quality modeling inputs including annual meteorology and emissions inventories for a 2002 actual emissions base case, a planning case to represent the 2000-2004 regional haze baseline period using averages for key emissions categories, and a 2018 base case of projected emissions determined using factors known at the end of 2005 . All emi ssion inventories were prepared for CMAQ using the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system. Each of these inventories underwent a number of revisions throughout the development process to arrive at the final versions used in CMAQ modeling. The development of each of these emission scenarios is documented under the emissions inventory

sections of the TSS.

The 2018 visibility projections were made using the Plan02d and PRP 18b CMAQ 36 -km modeling results. Projections were made using relative response factors (RRFs) for each species:

1) RRF = [2018 Modeled Species/Baseline Modeled Species] 2) Projected Species Mass = Baseline IMPROVE Species x RRF 3) Projected Species Extinction = Conversion via IMPROVE Algorithm of Projected Species Mass

There are three RRF calculation methods. These methods differ in how the days for the calculation are selected. The Specific Days (EPA) meth od is the EPA default method, and single species’ RRFs are calculated across observed (IMPROVE) worst or best days in the base model year. The Specific Days (EPA) method was the method utilized by the State of Wyoming. The second method is the Quarterly Weighted method, whereby four quarterly species’ RRFs are calculated from the 20% worst or best days in each quarter, in spite of how those days compare to the overall annual worst and best days. The third method is the Monthly Weighted method, whereby twelve monthly species’ RRF are calculated from the 20% best or worst days in each month, regardless of how those days compare to the overall annual worst and best days.

More information on how to use the visibility tool in connection with RRF factors can b e found

at http://vista.cira.colostate.edu/tss/help/GettingStarted.aspx#MP , and specific information regarding how

RRF factors are calculated can be found in Section 6.4 o f the 2007 EPA document “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze” at http://www.epa.gov/scram001/guidance/guide/final-03- pm

- rh -guidance.pdf

. This EPA guidance was followed for setting up the “EPA Specific Days” option and other inputs

on the WRAP TSS Visibility Projections Tool, so all Class I areas in the WRAP region used

thei r IMPROVE site -specific monitoring and modeling data to derive the RRFs.

Generally, emissions inputs were prepared by individual states and tribes for point, area, and most dust emissions categories. The following WRAP Forums were relied upon to summariz e this data and provide it to the RMC:53  Point Source emissions were obtained from projects commissioned by the Stationary

Sources Joint Forum and the Emissions Forum.

 Area Source emissions were obtained from projects commissioned by the Stationary

Sources Joint Forum and the Emissions Forum.

 Mobile Source emissions were from projects commissioned by the Emissions Forum.

 Fire (natural and anthropogenic) emissions were from projects commissioned by the Fire

Emissions Joint Forum.

 Ammonia, Dust, and Biogenic e missions were from projects commissioned by the Dust Emissions Joint Forum and the Modeling Forum.

 Emissions from Pacific offshore shipping were from a project conducted by the RMC

. 1

 Other emissions from North America were from projects commissioned by the Emissions Forum and the Modeling Forum. The Mexico emissions are from 1999, and were held

constant for 2018. Canada emissions are from 2000 and were held constant for 2018.

 Boundary conditions reaching North America from the rest of the world were from a project commissioned by the VISTAS Regional Planning Organization, on behalf of the five regional planning organizations working on regional haze.

The results from the CMAQ regional modeling analysis are discussed later in this section.

Because some WR AP states are still going through the difficult case

- by

- case BART determinations for each EGU, the WRAP was not able to model all of the emission reductions from BART and State long- term strategies in the most recent modeling effort. Therefore, the modeling results and all graphics associated with the modeling results do not include BART and long-term strategy reductions proposed in this SIP or any other WRAP SIPs that were not

available at the time WRAP modeled . The WRAP was only able to include enforcea ble

reductions that were on the books at the time of the last model run.

5.2 Major Source Categories Contributing to Haze in Wyoming

Figures in this section show profiles of the relative contribution of in -state vs. out-of- state sources contributing to emissions in Wyoming’s Class I areas , for the 20% worst and best days, for the baseline (2000-2004) and future year (2018) scenarios, using the PSAT and WEP techniques. The Wyoming Class I areas are grouped by general location (based on representative IMP ROVE monitoring sites).

As previously described, there are several differences between the PSAT and WEP techniques. PSAT focuses on sulfate and nitrate contribution only, taking into account chemistry and deposition. PSAT also estimates the contribution from all regions

-- the WRAP states, CENRAP

states 2 , Canada, Mexico, Pacific offshore (shipping), and “outside the domain” (global transport). The WEP does not address sulfate and nitrate chemistry and deposition, and while it

1 See WRAP TSS website under “Resources”, “Emissions”, and “Offshore Emissions” for summary, or go to http://vista.cira.colostate.edu/docs/wrap/emissions/OffshoreEmissions.doc

.

2 CENRAP is a regional planning organization similar to the WRAP that is comprised of Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkan sas, and Louisiana.54 does estimate the contributio n from Canada and Pacific offshore regions, it does not include other regional contributions.

Based on these differences, the figures provided below focus on PSAT results for identifying the contribution of sulfates and nitrates (the primary anthropogenic source pollutants) and WEP results for identifying the contribution of organic carbon, elemental carbon, fine PM, and coarse PM (commonly associated with non-anthropogenic sources).

Sections 5.2.1 through 5.2.4 below show 20% worst- and best-day PSAT profiles on the contribution of sulfate and nitrate at each IMPROVE monitoring site representing the Class I areas in Wyoming. The pie charts display relative regional contributions to total annual modeled sulfate and nitrate mass at the respective sites. T he WRAP contribution is separated from the rest of the pie for easy identification. The remaining pie slices are outside the Western United States, for the regions described above.

The PSAT bar charts below the pie charts display source region and source category contributions of sulfate and nitrate mass. There are five source categories listed

-- point, area, mobile, anthropogenic fires (controlled burning), and natural and biogenic sources (mostly wildfire and windblown dust). Estimated contributions outside the modeling domain (Outside Domain) are also shown, and include Mexico, Canada, and Pacific offshore emissions.

Sections 5.2.5 through 5.2.12 present WEP profiles for organic carbon, elemental carbon, fine PM, and coarse PM, at Class I areas in Wyo ming.

Unlike the PSAT figures, the WEP figures are bar charts only and summarize weighted emissions by state and region for 12 source categories. These categories are windblown dust, fugitive dust, road dust, off-road mobile, on-road mobile, off-shore, W RAP area oil and gas, area, biogenic, natural fire, anthropogenic fire, and point. This analysis used more source categories than the PSAT analysis to account for the additional pollutant types, and the more natural origins contributing to these pollutants, including dust and fire sources.

5.2.1 PSAT Regional Contribution to Sulfate on 20% Worst Days

Figures 5.2.1-1 through 5.2.1-3 in this section illustrate the state and regional contribution of sulfate to the 20% worst days in Wyoming Class I areas for 2002 and 2018, based on PSAT profiles for each IMPROVE monitoring site representing the nearest Class I areas. The figures below consist of a pie chart that shows the estimated contribution of the major regions (WRAP states, Pacific Offshore, CENRAP, Ea stern U.S., Canada, Mexico, and Outside Domain (global)). The bar chart is the WRAP source region portion, depicting Wyoming and other

western states.

Note that in all the figures in this section, the majority of sulfate emissions originate outside the WRAP region. However, the nitrate contribution, discussed in Sections 5.2.3 and 5.2.4, is much higher within the WRAP region. The WRAP contribution is about one- third of the total, with the exception of the Bridger site, where the contribution is more than one- half. The largest contributor is outside the domain, or “global”. Among the other regions (not including the55 WRAP region), Canada, followed by Pacific Offshore and Mexico are the next sizable

contributors.

Also indicated in these figures, the largest contributor of sulfate is generally from point sources.

The variation in sulfate contribution is based on the location of the Class I area monitoring site in

the State. For example, the contribution of sulfate from Canada and Montana are the highest in the northernmost Class I area monitoring site, the North Absaroka Wilderness area. Similarly, the sulfate contribution from Mexico is highest in the southernmost Class I area monitoring site, the Bridger Wilderness area.

In terms of comparison of 2002 and 2018, it can be seen that the WRAP portion of the pie chart remains nearly unchanged , with only slight increases in 2018. The source category that accounts for this slight increase is primarily point.

Figure 5.2.1-1. PSAT Sulfate Contribution at Ye llowstone NP, Grand Teton NP, and Teton

Wilderness on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )56 It is interesting to note that for the 20% worst days at Yellowstone, the po int source sulfate contribution is approximately the same from Idaho as from Wyoming, most likely due to the proximity of industrial sources and wind direction. There is also a noticeable contribution from point sources in Canada, and a sizeable contribution from Mexico. Area and mobile sources from Wyoming and Idaho are much less. Close to half of the sulfate comes from the area outside

the domain.

Figure 5.2.1-2. PSAT Sulfate Contribution at North Absaroka Wilderness and Washak ie

Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

It should be noted that for the 20% worst days at North Absaroka, point source sulfate contribution is higher from Canada and Montana than from Wyoming, most likely due to the proximity of industrial sources and wind direction. There is a much larger sulfate contribution from Canada at the North Absaroka monitoring site than the other two monitoring sites (Yellowstone and Bridger). Area and mobile sources are very minimal contributors to sulfate in Wyoming. Approximately one half of the sulfate source is generated from the area outside the

domain.57 Figure 5.2.1-3. PSAT Sulfate Contribution at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst days at the Bridger monitoring site, overall sulfate levels are slightly higher compared to the Yellowstone and North Absaroka monitoring sites. The majority of the sulfate originates from point sources in Wyoming, Idaho, and Utah. There are also considerable contributions from Canada and Mexico. Area and mobile sources, again, contribute a small amount of sulfate in Wyoming. Approximately one-third of the sulfate is generated from the

area outside the domain.

5.2.2 PSAT Regional Contribution to Sulfate on 20% Best Days

Figures 5.2.2-1 through 5.2.2-3 in this section illustrate the state and r egional contribution of sulfate to the 20% best days in Wyoming Class I areas for 2002 and 2018, based on PSAT profiles for each IMPROVE monitoring site representing the nearest Class I areas. The figures below consist of a pie chart that shows the estima ted contribution of the major regions (WRAP states, Pacific Offshore, CENRAP, Eastern U.S., Canada, Mexico, and Outside Domain58 (global)). The bar chart is the WRAP source region portion, depicting Wyoming and other

western states.

Note that in all the figures in this section, the majority of sulfate emissions originate outside the WRAP region. However, the nitrate contribution, discussed in Sections 5.2.3 and 5.2.4, is much higher within the WRAP region. The WRAP contribution is about one-third to just less than

one- half of the total . The largest contributor is outside the domain, or “global”. Among the other regions (not including the WRAP region), Canada, followed by Pacific Offshore are the

next sizable contributors.

Also indicated in these figures, the largest contributor of sulfate is generally from point sources.

The variation in sulfate contribution is based on the location of the Class I area monitoring site in

the S tate. For example, the contribution of sul fate from Canada is the highest in the northernmost Class I area monitoring site, the North Absaroka Wilderness area. Similarly, the

sulfate contribution from Idaho is highest in the southernmost Class I area monitoring site, the Bridger Wilderness area.

In terms of comparison of 2002 and 2018, it can be seen that the WRAP portion of the pi e chart

increases only slightly in 2018. The source category that accounts for this slight increase is primarily point.59 Figure 5.2.2-1. PSAT Sulfate Contribution at Yellowston e NP, Grand Teton NP, and Teton

Wilderness Area on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

It is interesting to note that for the 20% best days at Yellowstone, the point s ource sulfate contribution is approximately four times greater from Idaho and more than twice as much from Canada as from Wyoming, most likely due to the proximity of industrial sources and wind direction. There are also noticeable contributions from point sources in Utah, Montana, Nevada, Washington and Oregon. The largest area and mobile source contribution comes from Idaho, followed by Pacific Offshore and Canada. About half of the sulfate comes from the area outside

the domain.60 Figure 5.2.2-2. PSAT Sulfate Contribution at North Absaroka Wilderness and Washak ie

Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

It should be noted that for the 20% best days at North Absaroka, point source sulfate contribution is several times higher from Canada and Idaho than from Wyoming, most likely due to the proximity of industrial sources and wind direction. There is a much larger sulfate contribution

from Canada at the North Absaroka monitoring site than the other two monitoring sites (Yellowstone and Bridger). Area and mobile sources are very minimal contributors to sulfate in Wyoming. Approximately one half of the sulfate source is generated from the area outs ide the

domain.61 Figure 5.2.2-3. PSAT Sulfate Contribution at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For th e 20% best days at the Bridger monitoring site, overall sulfate levels are approximately the same as Yellowstone and slightly lower than the North Absaroka monitoring site. The majority of the sulfate originates from point sources in Idaho, with much smal ler amounts from Wyoming,

Utah , and Nevada , respectively . Area and mobile sources, again, contribute a small amount of sulfate in Wyoming. Well over one- half of the sulfate is generated from the area outside the

domain.

5.2.3 PSAT Regional Contribution to Nitrate on 20% Worst Days

Figures 5.2.3-1 through 5.2.3-3 in this section illustrate the state and regional con tribution of nitrate to the 20% worst days in Wyoming Class I areas for 2002 and 2018, based on PSAT profiles for each IMPROVE monitoring si te representing the nearest Class I areas.

In all the figures in this section, most of the nitrate originates from within the WRAP region, as opposed to the sulfate contribution, which is mostly derived from outside the WRAP. The WRAP contribution ranges from approximately one-half to nearly three- quarters of the total.62 Other sizeable contributions of nitrate are generated from outside the domain, and to a much lesser extent, Canada and Pacific offshore. Contributions from other regions are negligible.

These figures indicate that overall, the majority of nitrate stems from mobile sources. In all but one of the Class I area monitors (Bridger), contributions from other states and Canada are much larger than contributions from inside Wyoming.

In terms of comparison of 2002 and 2018, these figures indicate that the WRAP portion of the pie chart has a significant decrease in nitrate by 2018. Most of this decrease can be attributed t o the numerous F ederal and state “on -the-books” requirements for mobile sou rces (see Chapter 8

, Long

- Term Strategy).

Figure 5.2.3-1. PSAT Nitrate Contribution at Yellowstone NP, Grand Teton NP, and Teton

Wilderness Area on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst days at Yellowstone, significant nitrate contributions can be seen from Idaho, Washington, and to a lesser extent, Oregon, Utah and Wyoming. Mobile sources make up the majority of the overall contributions. However, the projected 2018 area source contributions for63 Idaho and Wyoming exceed the mobile source contribution. In most cases, nitrate contributions are projected to decline significantly by 2018, with the exception of a small increase within Wyoming.

Figure 5.2.3-2. PSAT Nitrate Contribution at North Absaroka Wilderness and Washak ie

Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst days, s ignifica nt nitrate contributions for North Absaroka can be seen from Idaho, Montana, and Canada. The extent of contribution from Montana and Canada is greater at this monitoring site due to their close proximity. The extent of Idaho’s contribution is less at thi s site compared to the Yellowstone site, also due to proximity. Smaller contributions of nitrate originate from Wyoming, Washington, Utah, and Oregon. Mobile sources appear to be the dominant contributor overall; however, point sources in Montana are a l arge factor.64 Figure 5.2.3-3. PSAT Nitrate Contribution at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Unlike Yell owstone and North Absaroka, for the 20% worst days the largest nitrate contribution for Bridger originates within Wyoming. Point sources in 2002 and projected area and point sources in 2018 appear to be the largest contributors within Wyoming. The next h ighest contribution comes from Utah, followed by Idaho. It is interesting to note that contributions from California (mostly mobile source) in 2002 were greater than contributions from Canada or

Montana.

5.2.4 PSAT Regional Contribution to Nitrate on 20 % Best Days

Figures 5.2.4-1 through 5.2.4-3 in this section illustrate the state and regional contribution of nitrate to the 20% best days in Wyoming Class I areas for 2002 and 2018, based on PSAT profiles for each IMPROVE monitoring site representing the nearest Class I areas.

In all the figures in this section, most of the nitrate originates from within the WRAP region, as opposed to the sulfate contribution, which is mostly derived from outside the WRAP. The65 WRAP contribution ranges from approximately one-half to nearly three- quarters of the total. Other sizeable contributions of nitrate are generated from outside the domain, and to a much lesser extent, Canada and Pacific offshore. Contributions from other regions are negligible.

These figures indi cate that overall, the majority of nitrate stems from mobile sources. Point and area sources are the next largest categories of nitrate contribution, especially at the Bridger monitoring site, where Wyoming’s area and point source contribution is the most sizeable. In all

but one of the Class I area monitors (Bridger), contributions from other states and Canada are much larger than contributions from inside Wyoming.

In terms of comparison of 2002 and 2018, these figures indicate that the WRAP portion of the pie chart has a significant decrease in nitrate by 2018. Most of this decrease can be attributed to

the numerous F ederal and state “on -the-books” requirements for mobile sources (see Chapter 8

, Long

- Term Strategy).

Figure 5.2.4-1. PSAT Nitrate Contr ibution at Yellowstone NP, Grand Teton NP, and Teton

Wilderness Area on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )66 For the 20% best days at Yellowstone, significant nitrate c ontributions can be seen from Idaho, Utah, California and Washington, and to a lesser extent, Canada, Montana, Oregon and Wyoming. Mobile sources make up the majority of the overall contributions. Nitrate contributions are projected to decline significantly by 2018.

Figure 5.2.4-2. PSAT Nitrate Contribution at North Absaroka Wilderness and Washak ie

Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% best days, significant nitrate contributions for North Absaroka can be seen from Idaho, Canada, Utah, California and Montana. The extent of contribution from these states and

Canada is due in part to wind direction and proximity. The extent of Idaho’s co ntribution is less at this site compare d to the Yellowstone site, due mostly to proximity. Smaller contributions of nitrate originate from Washington, Nevada, Oregon , Wyoming and North Dakota. Mobile sources appear to be the dominant contributor overall; however, point sources in Utah and

California and area sources in Idaho and Canada are a large factor.67 Figure 5.2.4-3. PSAT Nitrate Contribution at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Best Visibility D ays

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% best days the largest nitrate contribution for Bridger originates within Utah. Mobile and point sources appear to be the largest contributors within Utah. The next highest contribution comes from Idaho, followed by Wyoming and California. It is interesting to note that contributions from California (mostly mobile source) were greater than contributions from

Canada or Montana.

5.2.5 WEP Potential Contribution to OC on 20% Worst Days

Figures 5.2.5-1 through 5.2.5-3 in this section represent the contribution of organic carbon to the 20% worst days in Wyoming Class I areas for 2002 and 2018, based on the WEP profile for each IMPROVE monitoring site representing the ne arest Class I areas.

In general, the figures below primarily reflect the contribution of fire sources - mostly natural fire (wildfire) and to a lesser degree, anthropogenic or controlled burning (forestry, agricultural, and residential burning). Area source organic carbon is from woodstoves and other urban related68 sources. Area source contributions of organic carbon are the low est at the Yellowstone Class I area monitoring site due to its location, which is not near any urban areas.

When comparing 2002 and 2018, the figures show a slight reduction in future years, mainly due to a projected drop in anthropogenic fires. Most other sources remain fairly constant.

T he WRAP TSS website states that the Primary Organic Aerosol parameter represents organic carbon compounds emitted directly as particulates, but not secondary organics which condense from a gaseous state after being emitted.

Figure 5.2.5-1. WEP Potential Contribution to OC at Yellowstone NP, Grand Teton NP,

and Teton Wilderness Area on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst visibility days at Yellowstone, the most sizeable organic carbon contribution

is from Wyoming natural fire sources, and to a minimal extent, anthropogenic fire followed by

area sources. A much smaller contribution from these sources in Idaho can be seen.69 Figure 5.2.5-2. WEP Potential Contribution to OC at North Absaroka Wild erne ss and

Washakie Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst visibility days at North Absaroka, the most sizeable organic carbon contribution is from Wyoming natural fire sources, and to a minimal extent, anthropogenic fire followed by area sources. However, a large contribution from these sources also comes from Idaho, followed by Montana, and to a les ser extent, Oregon.

Figure 5.2.5-3. WEP Potential Contribution to OC at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://v ista.cira.colostate.edu/tss/ )

For the 20% worst visibility days at Bridger, the most sizeable organic carbon contribution is from Wyoming natural fire sources, and to a minimal extent, area sources, followed by70 anthropogenic fire. Idaho, Oregon, Utah and California are the next largest contributors, respectively.

5.2.6 WEP Potential Contribution to OC on 20% Best Days

Figures 5.2.6-1 through 5.2.6-3 in this section represent the contribution of organic carbon to the

20% be st days in Wyoming Class I ar eas for 2002 and 2018, based on the WEP profile for each IMPROVE monitoring site representing the nearest Class I areas.

In general, the figures below primarily reflect the contribution of fire sources - mostly natural fire (wildfire) and to a lesser degr ee, anthropogenic or controlled burning (forestry, agricultural, and residential burning). Area source organic carbon is from woodstoves and other urban related sources. Area source contributions of organic carbon are the lowest at the Yellowstone Class I area monitoring site due to its location, which is not near any urban areas.

When comparing 2002 and 2018, the figures show a slight reduction in future years, mainly due to a projected drop in anthropogenic fires. Most other sources remain fairly constant.

The WRAP TSS website states that the Primary Organic Aerosol parameter represents organic carbon compounds emitted directly as particulates, but not secondary organics which condense from a gaseous state after being emitted.

Figure 5.2.6-1. WEP Potential Contribution to OC at Yellowstone NP, Grand Teton NP,

and Teton Wilderness Area on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For t he 20% best visibility days at Yellowstone, the most sizeable organic carbon contribution is from Wyoming natural fire sources, and to a minimal extent, anthropogenic fire followed by area

sources. A much smaller contribution from these sources in Idaho c an be seen.71 Figure 5.2.6-2. WEP Potential Contribution to OC at North Absarok a Wilderness and

Washakie Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista .cira.colostate.edu/tss/ )

For the 20% best visibility days at North Absaroka, the most sizeable organic carbon contribution is from Wyoming natural fire sources, and to a minimal extent, anthropogenic fire followed by area sources. However, a contribution from these sources nearly equal in size comes from Idaho. Oregon , Montana and California, respectively, are the next largest

contributors.

Figure 5.2.6-3. WEP Potential Contribution to OC at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )72 For the 20% best visibility days at Bridger, the most sizeable organic carbon contribution is from Wyo ming natural fire sources, and to a minimal extent, area and anthropogenic fire sources

. Idaho, Oregon, California and Utah are the next largest contributors, respectively.

5.2.7 WEP Potential Contribution to EC on 20% Worst Days

Figures 5.2.7-1 through 5.2.7-3 in this section represent the contribution of elemental carbon to the 20% worst days in Wyoming Class I areas for 2002 and 2018, based on the WEP profile for each IMPROVE monitoring site representing the nearest Class I areas.

In general, the figures below primarily reflect the contribution of fire sources - mostly natural fire (wildfire) and to a much lesser degree, off -road mobile and anthropogenic or controlled burning (forestry, agricultural, and residential burning). Off -road mobile element al carbon contributions are minimal to none at Yellowstone compared to North Absaroka and Bridger.

When comparing 2002 and 2018, the figures show a reduction in future years, mainly due to a projected drop in off-road mobile and anthropogenic fire emissio ns. Most other sources remain fairly constant.

Figure 5.2.7-1. WEP Potential Contribution to EC at Yellowstone NP, Grand Teton NP,

and Teton Wilderness Area on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst visibility days at Yellowstone, the most sizeable elemental carbon contribution is from Wyoming natural fire sources, and to a minimal extent, anthropogenic fire

. A much smaller contribution from these sources, except for off-road mobile, can be seen in

Idaho.73 Figure 5.2.7-2. WEP Potential Contribution to EC at North Absaroka Wilderness and

Washakie Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

At North Absaroka for the 20% worst visibility days, natural fire source s from Wyoming is the largest contributor to elemental carbon , followed b y anthropogenic fire and off-road mobile, and to a much lesser extent, area sources and on

- road mobile . Idaho contributes a significant amount of these sources, followed by Montana and to a lesser extent, Oregon. California, Washington and Utah, respecti vely, also show some measurable contributions from these sources.

Figure 5.2.7-3. WEP Potential Contribution to EC at Bridger Wilderness and Fitzpatrick

Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )74 For the 20% worst visibility days at Bridger, Wyoming is the largest contributor. Natural fire is the largest component of contribution followed by off-road mobile, anthropogeni c fire, area and on-road mobile, respectively. Idaho, Utah, Oregon and California, respectively, have the next

sizeable contributions from these sources at this site.

5.2.8 WEP Potential Contribution to EC on 20% Best Days

Figures 5.2.8-1 through 5.2.8-3 in this section represent the contribution of elemental carbon to the 20% best days in Wyoming Class I areas for 2002 and 2018, based on the WEP profile for each IMPROVE monitoring site representing the nearest Class I areas.

In general, the figures below primarily reflect the contribution of fire sources - mostly natural fire (wildfire) and to a much lesser degree, off-road mobile and anthropogenic or controlled burning (forestry, agricultural, and residential burning). Off- road mobile elemental carbo n contributions are smaller at Yellowstone compared to North Absaroka and Bridger.

When comparing 2002 and 2018, the figures show a reduction in future years, mainly due to a projected drop in off-road mobile and anthropogenic fire emissions. Most other sources remain fairly constant.

Figure 5.2.8-1. WEP Potential Contribution to EC at Yellowstone NP, Grand Teto n NP,

and Teton Wilderness Area on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% best visibility days at Yellowstone, the most sizeable elemental carbon contribution is from Wyoming natural fire sources, and to a minimal extent, anthropogenic fire followed by

off -road mobile. A smaller contribution from these sources, except for off-road mobile, can be

seen in Idaho.75 Figure 5.2.8-2. WEP Potential Contribution to EC at North Absaroka Wilderness and

Washakie Wilderness Areas on 20% Best Visibili ty Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

At North Absaroka for the 20% be st visibility days, natural fire sources from Wyoming, Idaho, Oregon and Montana are the largest contributor s to elemental carbon. The next largest source is

off -road mobile, mainly originating in Idaho and Utah. A nthropogenic fire , area sources and onroad mobile contribute to a much smaller degree in comparison to natural fire and off-road

mobile. Idaho contr ibutes the most significant amount of elemental carbon overall, followed by Wyoming, Oregon, Montana, Utah and California, respectively.

Figure 5.2.8-3. WEP Potential Contribution to EC at Bridger Wilderness and Fitzpatrick

Wil derness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )76 For the 20% best visibility days at Bridger, Wyoming is the largest contributor. Natural fire is the larges t component of contribution followed by off-road mobile, anthropogenic fire, area and on-road mobile, respectively. Idaho, Utah, Oregon and California, respectively, have the next

sizeable contributions from these sources at this site.

5.2.9 WEP Potenti al Contribution to Fine PM on 20% Worst Days

Figures 5.2.9-1 through 5.2.9-3 in this section illustrate the contribution of fine PM to the 20% worst days in Wyoming Class I areas for 2002 and 2018, based on the WEP profile for each IMPROVE monitoring site representing the nearest Class I areas.

In general, the figures below represent contributions which consist predominantly of dust sources (mining, construction, unpaved roads and agriculture ), with smaller contributions from area sources (woodstoves, etc.) and point sources, followed by natural fire and anthropogenic fire. Note that the largest contribution from natural fire in all three figures originates in Wyoming

, with the most sizeable contribution affecting the Yellowstone monitoring site

.

When co mparing 2002 and 2018, these figures indicate a consistent increase in most cases in fine PM emissions, primarily from dust sources. However, at the Bridger site, a small increase in point source contribution is noted.

Figure 5.2.9-1. WEP Potential Cont ribution to Fine PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

The 20% worst vis ibility days at Yellowstone are dominated by fine PM contributions from dust

sources in Idaho and Montana. Idaho also contributes a sizeable amount of fine PM area source

emissions. Wyoming’ s fine PM contributions are slightly hig her than Montana’s, but originate mainly from natural fire sources, followed by dust sources. Less significant PM contributions from dust sources are noted in Washington, Oregon, Canada, and Utah, respectively.77 Figure 5.2.9-2. WEP Potential Contributions to Fine PM at Nort h Absaroka Wilderness

and Washakie Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Dust sources in Montana are the overwhelmi ng fine PM contributor for the 20% worst visibility days at North Absaroka , mainly due to the proximity of the monitoring site . The next largest contributor is Idaho, followed closely by Wyoming and Canada. The second largest source in Wyoming is natural fire, and in Idaho and Montana it is area sources. Dust sources in Washington and Oregon contribute to fine PM at North Absaroka, but to a much lesser degree.

Figure 5.2.9-3. WEP Potential Contribution to Fine PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )78 For the 20% worst visibility days at Bridger, Wyoming is the dominant contribu tor to fine PM. Contributions are split fairly evenly between dust sources, point sources and natural fire, with dust sources being slight ly more predominant. Idaho has quite sizeable contributions consisting of dust sources, followed by area sources. Utah is the next largest contributor with dust sources followed by point sources making up the majority of the components. Montana, Oregon, Washington, California and Canada , respectively, all have sizeable contributions of fine PM as

well.

5.2.10 WEP Potential Contribution to Fine PM on 20% Best Days

Figures 5.2.10-1 through 5.2.10-3 in this section illustrate the contri bution of fine PM to the 20% best days in Wyoming Class I areas for 2002 and 2018, based on the WEP profile for each IMPROVE monitoring site representing the nearest Class I areas.

In general, the figures below represent contributions which consist predominantly of dust sources (mining, construction, unpaved roads and agriculture), with smaller contributions from area sources (woodstoves, etc.) and point sources, followed by natural fire and anthropogenic fire. Note that the largest contribution from natural fire in all three figures originates in Wyoming, with the most sizeable contribution affecting the Yellowstone monitoring site.

Wh en comparing 2002 and 2018, these figures indicate a consistent increase in most cases in fine PM emissions, primarily from dust sources. However, in all three figures , a small increase in point source contribution is noted.

Figure 5.2.10-1. WEP Potenti al Contribution to Fine PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

The 2 0% best visibility days at Yellowstone are dominated by fine PM contributions from dust sources in Idaho, Wyoming and Montana. Idaho also contributes a sizeable amount of fine PM area source emissions. Wyoming’s fine PM contributions originate mainly fro m natural fire79 sources, followed by dust sources. Significant PM contributions from dust sources are also noted in Utah and Oregon, and to a lesser degree in California, Canada, Washington and Nevada.

Figure 5.2.10-2. WEP Potential Contribution to Fine PM at North Absaroka Wilderness

and Washakie Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Dust sources in Montana and Idaho are the overwhelming fine PM contributors for the 20% best visibility days at North Absaroka. The next largest contributor is Wyoming, followed clo sely by Utah, Oregon, Canada, Washington and California, respectively. The second largest source in Wyom ing is natural fire, and in Montana and Idaho it is area sources.

Figure 5.2.10-3. WEP Potential Contribution to Fine PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )80 For the 20% best visibility days at Bridger, Idaho is the dominant contributor to fine PM, followed by Wyoming and Utah. Dust sources are predominant, followed by natura l fire, point,

and area sources. Montana, Oregon, California, Nevada and Washington, respectively, are the next largest contributors. Dust sources, followed by area and point sources , make up the majority of the contribution components from these states.

5.2.11 WEP Potential Contribution to Coarse PM on 20% Worst Days

Figures 5.2.11-1 through 5.2.11-3 in this section illustrate the contribution of coarse PM to the 20% worst days in Wyoming Class I areas for 2002 and 2018, based on WEP profiles for each IMPROVE monitoring site representing the nearest Class I areas.

The figures below show that the profile for coarse PM is dominated by road dust, windblown dust, and to a lesser extent, fugitive dust. These dust sources are generated mainly from Montana and Idaho, with the exception of the Bridger site, where most of the coarse PM emissions are generated in Wyoming. These dust sources are a combination of natural and human activity, such as construction, mining, unpaved and paved roads, and agriculture. There is some contribution from natural fire sources, mainly from Wyoming and Idaho, as well as contributions from point sources in Wyoming, Utah and Montana.

When comparing 2002 and 2018, most figures show increases in fugitive dust and road dust mainly due to population growth. Windblown dust remains constant in all figures.

Figure 5.2.11-1. WEP Potential Contribution to Coarse PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% worst visibility days at Yellowstone, the most sizeable coarse PM contributions are from dust sources originating in Montana and Idaho. Wyo ming is the third largest contributor of coarse PM, with slightly less than 50% coming from natural fire sources and the remainder81 mainly from dust sources. To a much lesser extent, Utah, Oregon, Washington and Canada also contribute coarse PM to the Yellowstone monitoring site.

Figure 5.2.11-2. WEP Potential Contribution to Coarse PM at North Absaroka Wilderness

and Washakie Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Dust sources from Montana, by far, are the largest contributor to coarse PM on the 20% worst visibility days at North Absaroka. Idaho and Wyoming are the next largest contributors, followed by Canada.

Fi gure 5.2.11-3. WEP Potential Contribution to Coarse PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Worst Visibility Days

(WRAP TSS

- http://vista.cira.col ostate.edu/tss/ )82 For the 20% worst visibility days at Bridger, Wyoming is the largest contributor of coarse PM, followed closely by Idaho, Utah and Montana, respectively. Point and natural fire sources from Wyoming comprise approximately one-third of the coarse PM contribution, while dust sources make up roughly two-thirds of the contribution. Oregon, Canada, California, Washington and

Nevada contribute coarse PM to a much lesser extent at this site.

5.2.12 WEP Potential Contribution to Coarse PM on 20% Best Days

Figures 5.2.12-1 through 5.2.12-3 in this section illustrate the contribu tion of coarse PM to the 20% best days in Wyoming Class I areas for 2002 and 2018, based on WEP profiles for each IMPROVE monitoring site representing the nearest Class I areas.

The figures below show that the profile for coarse PM is dominated by road dust, windblown dust, and to a lesser extent, fugitive dust. These dust sources are generated mainly from Montana and Idaho, with the exception of the Bridger site, where most of the coarse PM

em issions are generated in Idaho, Wyoming and Utah, respectively. Montana generates approximately one-third of the amount of dust compared to Idaho at the Bridger monitoring site. These dust sources are a combination of natural and human activity, such as construction, mining, unpaved and paved roads, and agriculture. There is some contribution from natural fire sources, mainly from Wyoming and Idaho, as well as smaller contributions from point sources in Utah, Wyoming, and Montana.

When comparing 2002 and 2018, most figures show increases in fugitive dust and road dust mainly due to population growth. Windblown dust remains constant in all figures.

Figure 5.2.12-1. WEP Potential Contribution to Coarse PM at Yellowstone NP, Grand Teton NP, and Teton Wilderness Area on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

For the 20% best visibility days at Yellowstone, the mo st sizeable coarse PM contributions are from dust sources origina ting in Idaho and Montana. Wyoming is the third largest contributor of83 coarse PM, with approximately 50% coming from natural fire sources and 50% from dust sources. Utah is the fourth largest contributor, with the majority attributable to dust sources, and a smaller amount coming from point sources. To a much lesser extent, Oregon, Canada , Nevada, California and Washington also contribute coarse PM to the Yellowstone monitoring site.

Figur e 5.2.12-2. WEP Potential Contribution to Coarse PM at North Absaroka Wilderness

and Washakie Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista.cira.col ostate.edu/tss/ )

Dust sources from Montana and Idaho are the largest contributors to coarse PM on the 20% best visibility days at North Absaroka. Wyoming and Utah are the next largest contributors, followed by Oregon, Canada and Washington.84 Figure 5.2.12-3. WEP Potential Contribution to Coarse PM at Bridger Wilderness and Fitzpatrick Wilderness Areas on 20% Best Visibility Days

(WRAP TSS

- http://vista. cira.colostate.edu/tss/ )

For the 20% best visibility days at Bridger, Idaho is the largest contributor of coarse PM, followed by Wyoming, Utah and Montana, respectively. Dust sources are the dominant component of the coarse PM emissions at the Bridger site, followed by natural fire and point

sources.

5.3 CMA Q 2018 Projected Visibility Conditions

This section summarizes the regional haze improvements projected using the CMAQ model for Wyoming’s Class I areas. The CMAQ model was used to estimate 2018 v isibility conditions in Wyoming and all W estern Class I areas, based on emission inputs described in Section 5.1.2 of this chapter. The Division relied upon the results of the CMAQ modeling in establishing the Reasonable Progress Goals described in Chapter 7.

These visibility projections were calculated from modeled results by multiplying a species

specific relative response factor (RRF) with the baseline monitored result, and then converting to

extinction and deciview. The RRF is defined as the ratio of future- to -current modeled mass. Chapter 7 details how the 2018 projected visibility conditions were used for setting Reaso nable Progress Goals. Analysis of the WRAP 2018 preliminary reasonable progress modeling runs are contained in an August 2009 ENVIRON Memorandum in Chapter 5 of the Wyoming TSD.

Table 5.3-1 shows the 2018 visibility projections for the 20% worst and best days, compared to the 2018 Uniform Rate of Progress (URP) for Wyoming Class I areas (grouped by IMPROVE monitoring site). These 2018 projections are shown in deciview, and in the percent of the URP achieved by 2018 for the 20% worst days (first shaded column). Also indicated is whether the 20% best days for 2018 are projected to be under the 2000-2004 baseline (second shaded column).85 This table shows that Wyoming’s Class I areas are slightly less than half way to meeting the 2018 URP for the 20% worst days. Section 5.3.1 provides a breakdown by pollutant species to analyze the cause of this. For the 20% best days, all Class I area s are under the baseline, and thus show no visibility degradation by 2018.

Table 5.3-1. CMAQ Modeling Results for 20% W orst Days and 20% Best Days for Wyoming Class I Areas

Wyoming Class I Area 20% Worst Days 20% Best Days

2000

- 04

Baseline

(dv) 2018

URP

Goal (dv) 2018 Projected Visibility (dv) % of

2018

URP

Goal 2000

- 04

Baseline

(dv) 2018 Projected Visibility (dv) 2018

Under

Baseline?

Yellowstone National Park

Grand Teton National Park

Teton Wilderness 11.8 10.5 11.2 46 % 2.6 2. 4 Y es

North Absaroka Wilderness

Washakie Wilderness 11.5 10.4 11.0 45 % 2.0 2.0 Yes

Bridger Wilderness Fitzpatrick Wilderness 11.1 10.0 10. 6 45 % 2.1 2.0 Yes

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

5.3.1 CMAQ Modeling Breakdown by Pollutant for 20% Worst Days

As indicated by the 2018 visibility projections using CMAQ modeling, none of the Class I areas meet the URP goal for 2018 for the 20% worst days. In order to determine the cause, it is necessary to break down these results to identify individual pollutants. The information provided below shows the contribution of each pollutant in e xtinction (Mm

- 1) to the total extinction level for each Class I area. As pointed out earlier in this chapte r, it is important to note whether the pollutants affecting the modeling are anthropogenic, such as sulfates or nitrates, or the other pollutants that are mostly natural in origin (OC, EC, and PM). This assessment is important in

the determination of reas onable progress, described in Chapter 7.

Figures 5.3.1-1 through 5.3.1-3 provide a breakdown of individual pollutant contribution (in extinction) by showing the glide slope of each pollutant in each Class I area , from the baseline to 2018, and beyond, for the 20% worst days. Below each figure is a table that shows the 2018 projections for each pollutant, and whether the projection is under the 2018 URP goal, and the percent improvement toward the 2018 URP goal.

The results of this breakdown by pollutant shows that at all Class I areas, nitrate exceeds or

meets the 2018 URP goal . For sulfate, while none of the Class I areas meet the 2018 URP goal, the improvement is as high as 82 % at the Bridger Class I area. Conversely, these tables and figures show that organic carbon is the highest contributor to extinction, and projections for 2018 show very little improvement. Much of the organic carbon can be attributed to fire, of which the majority is wildfire, and thus non-anthropogenic in origin. For fine soil there is no progress toward the 2018 URP goal because the projected 2018 values are higher than or equal to baseline

conditions. Chapter 7 provides further discussion related to Reasonable Progress Goal

demonstration.86 Figure 5.3.1-1. Glide Slope by Pollutant on 20% Worst Days for Yellowstone NP, Grand

Teton NP, and Teton Wilderness Area

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Table 5.3.1-1. Pollutant Breakdown on 20% Worst Days for Yellowstone NP, Grand Teton NP, and Teton Wilderness Area

Pollutant Yellowstone NP, Grand Teton NP, and Teton Wilderness Area

2000-04

Baseline (Mm

- 1) 2018

URP

Goal (Mm

- 1) 2018 Projected Visibility

(Mm

- 1) 2 064

Natural

Conditions

(Mm

- 1) 2018

Under

URP

Goal? % of

URP

Goal

Sulfate 4.3 3.4 3.7 0.8 No 67 %

Nitrate 1.8 1.5 1.4 0.6 Yes >100% Organic

Carbon 13.5 11.0 12.9 4.6 No 24%

Elemental

Carbon 2.5 2.0 2.2 0.4 No 60%

Fine Soil 1.0 1.0 1.0 1.0 Yes None*

Coa rse Material 2.6 2.7 2.6 3.0 Yes >100%

Sea Salt 0.0 0.0 0.0 0.0 Yes 100% *No progress towards URP goal because projected 2018 values are higher than or equal to baseline

conditions. (WRAP TSS

- http: //vista.cira.colostate.edu/tss/ )87 Figure 5.3.1-2. Glide Slope by Pollutant on 20% Worst Days for North Absaroka and

Washakie Wilderness Areas

(WRAP TSS

- http://vista. cira.colostate.edu/tss/ )

Table 5.3.1-2. Pollutant Breakdown on 20% Worst Days for North Absaroka and

Washakie Wilderness Area

Pollutant North Absaroka and Washakie Wilderness Areas

2000-04

Baseline (Mm

- 1) 2018

URP

Goal (Mm

- 1) 2018 Projected Visibility

(Mm

- 1) 2064

Natural

Conditions

(Mm

- 1) 2018

Under

URP

Goal? % of

URP

Goal

Sulfate 4. 9 3.8 4. 5 0.8 No 45 %

Nitrate 1.6 1.4 1. 3 0. 8 Yes > 100% Organic

Carbon 11.6 9.8 11.0 4.6 No 33%

Elemental

Carbon 1.9 1.5 1.6 0.4 No 75%

Fine So il 0. 9 0. 9 1.0 0.9 No None *

Coarse

Material 2.9 3.0 2.9 3.4 Yes >100%

Sea Salt 0.0 0.0 0.0 0.0 Yes 100% *No progress towards URP goal because projected 2018 values are higher than or equal to baseline

conditions. (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )88 Figure 5.3.1-3 . Glide Slope by Pollutant on 20% Worst D ays for Bridger and Fitzpatrick

Wilderness Areas

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Table 5.3.1-3. Pollutant Breakdown on 20% Worst D ays for Bridger and Fitzpatrick

Wilderness Areas

Pollutant Bridger and Fitzpatrick Wilderness Areas

2000-04

Baseline (Mm

- 1) 2018

URP

Goal (Mm

- 1) 2018 Projected Visibility

(Mm

- 1) 2064

Natural

Conditions

(Mm

- 1) 2018

Under

URP

Goal? % of

URP

Goal

Sulfate 5.0 3. 9 4. 1 0.8 No 82 %

Nitrate 1.4 1. 3 1. 2 0. 8 Yes > 100 % Organic

Carbon 10.6 9.0 10.3 4.6 No 19%

Elemental

Carbon 2.0 1.6 1.8 0.4 No 50%

Fine Soil 1.1 1.1 1.2 1. 1 No None*

Coarse

Material 2.5 2.6 2.5 2.7 Yes >100%

Sea Salt 0.0 0.0 0.0 0.0 Yes 100% *No progress towards URP goal because projected 2018 values are higher than or equal to baseline

conditions. (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )89 

### CHAPTER 6 BEST AVAILABLE RETROFIT TECHNOLOGY (BART)

6.1 Introduction

One of the principal elements of Section 169A of the 1977 Clean Air Act Amendments addresses the installation of Best Available Retrofit Technology (BART) for certain existing sources of pollution. The provision, 169A(b)(2), demonstrates Congress’ intent to focus attention directly on pollution from a specific group of existing sources. The U.S . EPA’s Regional Haze Rule requires certain emission sources that may reasonably be anticipated to cause or contribute to visibility impairment in downwind Class I areas to install BART (see 40 CFR 51.308(e); see also 64 Fed. Reg. 35714 et seq. (July 1, 1999)). These requirements are intended to reduce emissions from certain large sources that, due to age, were exempted from other requirements of the Clean

Air Act.

BART requirements pertain to 26 specified major point source categories including power plants, cement kilns and industrial boilers. To be considered BART-eligible, sources from these categories must have the potential to emit 250 tons or more of haze forming pollution and must have commenced operation in the 15-year period prior to August 7, 1977.

In addition to source- by -source command and control BART implementation, EPA has allowed for more flexible alternatives if they achieve greater progress toward the S tate’s visibility goals than the standard BART approach.

On July 1, 1999, the EPA pu blished regulations to address regional haze visibility impairment. The regulations required states to address BART requirements for regional haze visibility impairment, and allowed nine western states to develop plans that were based on the GCVTC

recomme ndations for stationary SO 2 sources in lieu of BART.

In 2000 the Western Regional Air Partnership (WRAP) submitted an Annex to the GCVTC recommendations that provided more details regarding the regional SO 2 milestones and backstop trading program that had been recommended in the GCVTC Report, and included a demonstration that the milestones achieved greater reasonable progress than would have been achieved by the application of BART in the region. The Annex was approved by EPA in 2003, but this approval was later vacated by the DC Circuit Court of Appeals in 2005 due to problems with the methodology that was required in the regional haze rule for demonstrating greater reasonable progress than BART. 3

On July 6, 2005 EPA revised the Regional Haze Rule in r esponse to the judicial challenges to the BART requirements. On October 13, 2006 EPA published additional revisions to address

alternatives to source- specific BART determinations.

3 Center for Energy and Economic Development v. EPA, February 18, 2005; American Corn Growers Association v.

EPA , May 24, 2002.90 Five western states (Arizona, New Mexico, Oregon, Utah, and Wyoming) had s ubmitted State Implementation Plans (SIPs) in 2003 under 40 CFR 51.309. Four of those states (Arizona, New Mexico, Utah, and Wyoming) have updated their SIPs to include new SO 2 milestones that are

based on more recent emission inventories as well as the r evised BART requirements in the Regional Haze Rule. The fifth state, Oregon, is no longer participating in the program. Details

on the alternative to the BART program are contained in the 309 SIP submittal to EPA under a separate action.

6.2 SO 2 : Regi onal SO 2 Milestone and Backstop Trading Program

Wyoming is a §309 state participating in the Regional SO 2 Milestone and Backstop Trading Program. §308(e)(2) provides s tates with the option to implement or require participation in an emissions trading program or other alternative measure rather than to require sources subject to BART to install, operate, and maintain additional control technology to meet an established emission limit on a continuous basis. However, the alternate program must achieve great er reasonable progress than would be accomplished by installing BART. A demonstration that the alternate program can achieve greater reasonable progress is prescribed by §308(e)(2)(i). Since the pollutant of concern is SO 2 , this demonstration has been pe rfo rmed under §309 as part of the State Implementation P lan. §309(d)(4)(i) requires that the SO 2 mi lestones established under the Plan “...must be shown to provide for greater reasonable progress than would be achieved by application of BART pursuant to §51.308(e)(2).”

Wyoming participated in creating a detailed report entitled Demonstration T hat the SO 2 Milestones Provi de Greater Reasonable Progress T han BART covering SO 2 emissions from all states participating in the Regional SO 2 Milestone and Backstop Tr ading Program. The document was submitted to EPA in support of the §309 Wyoming Regional Haze SIP in

November of 2008.

As part of the §309 program, participating states, including Wyoming, must submit an annualRegional Sulfur Dioxide Emissions and Milestone Report that compares actual emissions to preestablished milestones. Participating states have been filing these reports since 2003. Each year,

states have been able to demonstrate that actual SO 2 emissions are well below the milestones.

The actual emissions and their respective milestones are shown below:

Table 6.2-1. Regional Sulfur Dioxide Emissions and Milestone Report Summary

Year Reported SO 2 Emissions (tons) 3

- year Milestone Average

(tons)

2003 330,679 447,383

2004 337,970 448,259

2005 3 04,591 446,903

2006 279,134 420,194

2007 273,663 420,637

In addition to demonstrating successful SO 2 emission reductions, §309 states have also relied on visibility modeling conducted by the WRAP to demonstrate improvement at Class I areas. The91 complete modeling demonstration showing deciview values was included as part of the visibility improvement section of the §309 SIP, but the SO 2 portion of the demonstration has been

included as Table 6.2-2 to underscore the improvements associated with SO 2 reductions.

Table 6.2-2. Visibility
- Sulfate Extinction Only

Class I Area Monitor

(Class I Areas Represented) 20% Worst Visibility Days (Monthly Average, Mm -1 ) 20% Best Visibility Days (Monthly Average, Mm -1 )

2018 1

Base Case (Base 18b) 2018 2
Preliminary

Reasonable Progress Case (PRP18 a ) 2018 1

Base Case (Base 18b) 2018 2
Preliminary

Reasonable Progress Case (PRP18 a ) Bridger, WY
(Bridger WA and Fitzpatrick WA) 5.2 4.3 1.6 1.3

North Absaroka, WY
(North Absaroka WA and Washakie WA) 4.8 4.5 1.1 1.1

Yellows tone, WY
(Yellowstone NP, Grand Teton NP and Teton WA) 4.3 3.9 1.6 1.4

Badlands, SD 17.8 16.0 3.5 3.1 Wind Cave, SD 13.0 12.1 2.7 2.5 Mount Zirkel, CO
(Mt. Zirkel WA and Rawah WA) 4.6 4.1 1.4 1.3

Rocky Mountain, CO 6.8 6.2 1.3 1.1

Gates of the Mountai ns, MT 5.3 5.1 1.0 1.0 UL Bend, MT 9.7 9.6 1.8 1.7 Craters of the Moon, ID 5.8 5.5 1.5 1.5 Sawtooth, ID 3.0 2.8 1.2 1.1 Canyonlands, UT
(Canyonlands NP and Arches NP) 5.4 4.8 2.1 1.9

Capitol Reef, UT 5.7 5.4 1.9 1.8

1 Represents 2018 Base Case growth plus all established controls as of Dec. 2004 . N o BART or S O 2 M ilestone assumptions were included.

2 Represents 2018 Preliminary Reasonable Progress growth estimates and established SO 2 limits (including milestone levels established at

the time of the model run)

.

All Class I areas in the surrounding states show a projected visibility improvement for 2018 with respect to SO 2 on the worst days and no degradation on the best days. More discussion on the visibility improvement of the §309 program can be found in the Wyoming §309 Regional Haze

SIP revision submitted to EPA in November 2008.

Therefore, in accordance with §308(e)(2), Wyoming’s §309 Regional Haze SIP, and WAQSR Chapter 6, Section 9, sources will not be required to install BART controls to m eet an SO 2 emission limit. Instead, sources will be required to participate in the Regional SO 2 Milestone and Backstop Trading Program authorized under Chapter 14 of the WAQSR.

The remainder of this section, therefore, focuses on how Wyoming has satisfied the BART requirements with respect to NO

x and PM in EPA’s Regional Haze Rule. Wyoming’s review process is described and a list of BART-eligible sources is provided. A list of sources that are subject to BART is also provided, along with the requisite modeling analysis approach and justification. Wyoming made its BART determinations using the methodology in EPA’s Guidelines for BART Determinations Under the Regional Haze Rule, 40 Fed. Reg. 39104 et seq.92 (July 6, 2005) (hereinafter “Appendix Y ”) , and the Wyoming Air Quality Standards and Regulations (WAQSR) Chapter 6, Permitting Requirements, Section 9, Best available retrofit technology (BART) . EPA’s Guidelines for BART Determinations and Chapter 6, Section 9 of the WAQSR can be found in Chapter 6 of th e Wyoming TSD.

6.3 Overview of Wyoming’s BART Regulation

Wyoming’s Environmental Quality Council approved a State-only BART regulation (Chapter 6, Permitting Requirements, Section 9, Best available retrofit technology (BART) ) on October 10, 2006, that became effective in December 2006. The provisions of the regulation required

BART -subject sources to submit an application, according to a schedule determined by the Air Quality Division, for a BART determination.

Wyoming’s BART Rule is based largely up on EPA’s BART Rule and related Appendix Y, which includes procedures to be followed when making BART determinations for individual sources. States are only required to follow Appendix Y procedures for sources which are electric generating units (EGUs) wit h greater than 750 MW generating capacity. EPA’s BART Rule has no specific requirements for conducting BART determinations for sources that are not electric generating plants with greater than 750 MW capacities. EPA encourages states to use its guidelines for all source categories, but states are not required to do so.

6.4 SIP BART Requirements From EPA’s Regional Haze Rule

The following sections address the SIP elements relative to BART contained in EPA’s Regional Haze Rule. Section numbers refer to provisions in section 308(e), the BART provision of the Regional Haze Rule.

308(e) (1)(i)

- A list of all BART

- eligible sources within the State.

The U.S. EPA regulations for best available retrofit technology (BART) are contained in 40 CFR part 51, Appendix Y, published July 6, 2005 in the Federal Register, and provide the guidelines for BART determinations. Section II of Appendix Y discusses a three-step procedure for identifying BART

- eligible sources. A source was BART -eligible if it 1) belonged to on e of the 26 listed categories, 2) was “in existence” on August 7, 1977, but not “in operation” before August 7, 1962, and 3) had the potential to emit greater than 250 tons per year of any single visibility impairing pollutant. If a facility met all three criteria mentioned, then a screening analysis was used to determine if it was “subject to BART”, per Section III of Appendix Y.

Using Appendix Y as a guideline, the State of Wyoming determined that there were fourteen (14) facilities with BART

- eligible e mission units. These facilities are listed below:

PacifiCorp

- Jim Bridger General Chemical PacifiCorp - Naughton P4 Production

FMC

- Granger OCI Wyoming

FMC

- Green River Dyno Nobel

Basin Electric

- Laramie River Sinclair

- Casper Refinery93 PacifiCorp - Wyodak Black Hills

- Neil Simpson 1 PacifiCorp - Dave Johnston Sinclair

- Sinclair Refinery

The Division completed a BART screening analysis on the fourteen facilities to determine which facilities had a significant impact on visibility in Class I areas in Wyoming, South Dakota, and

Colorado.

As specified in the Division’s BART Air Modeling Protocol dated March 2006 (see Chapter 6 of the Wyoming TSD), a source was deemed to produce a significant impact to visibility on a Cl ass I area if the source had a modeled impact to visibility value greater than 0.5 deciview (dv) to determine a daily maximum change in visibility ( Δ dv) value for each Class I area and year of meteorological data. The visibility impact threshold to determine BART sources is a 98 th

percentile change in visibility ( Δ dv) of 0.5 dv above background conditions. Therefore, if the 8 th

highest Δ dv value was equal to or greater than 0.5 dv, the source was considered to cause or contribute to visibility impairment in the subject Class I area, and therefore was “subject to BART”. However, if the 8 th highest value for all three years at each Class I area in a g iven domain was less than 0.5 dv, the source was not subject to BART. Using these criteria, the fourteen facilities were screened for BART subjectivity. The BART Facilities Emissions Inventory in Chapter 6 of the Wyoming TSD details the emission units at the BART

- eligible sources. Screening results, which provide the maximum change in visibility, number of days >0.5 dv, and 8 th high values, are summarized in the WY BART Screening Analysis Results and the WY BART Screening Analysis Results DV Frequency, which can also be found in Chapter 6 of the Wyoming TSD. After evaluating the results of the screening analysis, the following facilities were found to be subject to BART or not subject to BART.

Subject to BART Not Subject to BART PacifiCorp

- Jim Br idger P4 Production PacifiCorp - Naughton OCI Wyoming

FMC

- Granger Dyno Nobel

FMC

- Green River Sinclair

- Casper Refinery

Basin Electric

- Laramie River Black Hills

- Neil Simpson 1 PacifiCorp - Wyodak Sinclair

- Sinclair Refine ry PacifiCorp - Dave Johnston

General Chemical

308(e)(1)(ii) - A determination of BART for each BART- eligible source in the State that emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in an y mandatory Class I Federal area. All such sources are subject to BART.

The following table summarizes the Division’s BART determinations for sources that cause or contribute to visibility impairment in Class I areas. These BART determinations are part of this Regional Haze SIP that will be submitted to EPA.94 T able 6.4-1. BART Determinations for Wyoming Sources

Unit NO

x Control Type NO

x Emission

Limit Particulate Control Type PM 10 Emission

Limit (1)

Basin Electric

– Laramie (2)
River Unit 1 (550 MW) LNB + OFA 0.21 lb/MMBtu (30

- day rolling) ESP 0.030 lb/MMBtu

Basin Electric

– Laramie (2)
River Unit 2 (550 MW) LNB + OFA 0.21 lb/MMBtu (30

- day rolling) ESP 0.030 lb/MMBtu

Basin Electric

– Laramie (2)
River Unit 3 (550 MW) LNB + OFA 0.21 lb/MMBtu (30

- day rolling) ESP 0.030 lb/MMBtu

FMC Wyoming

– Granger 14 (358.5 MMBtu) n/a n/a n/a n/a

FMC Wyoming

– Granger 15 (358.5 MMBtu) n/a n/a n/a n/a

FMC Wyoming

– Westvaco

NS

- 1A (887 MMBtu) LNB + OFA 0.35 lb/MMBtu (30

- day rolling) ESP 0.05 lb/MMBtu

FMC Wyo ming

– Westvaco

NS

- 1B (887 MMBtu) LNB + OFA 0.35 lb/MMBtu (30

- day rolling) ESP 0.05 lb/MMBtu

FMC Wyoming

– Westvaco

PH

- 3 (333.6 MMBtu) n/a n/a n/a n/a

General Chemical

– Green

River GR -2- L (534 lb/MMBtu) LNB + S OFA or equivalent

technology 0.28 lb / MMBtu (30

- day rolling) ESP 0.09 lb/MMBtu

General Chemical

– Green

River GR -3- W (880 lb/MMBtu) LNB + S OFA or equivalent

technology 0.28 lb/MMBtu (30

- day rolling) ESP 0.09 lb/MMBtu

PacifiCorp

– Dave Johnston Unit 3 (230 MW) LNB + OFA 0.28 lb/MMBtu (30

- day rolling) Fabric Filter 0.015 lb/MMBtu

PacifiCorp

– Dave Johnston Unit 4 (330 MW) LNB + OFA 0.15 lb/MMBtu (30

- day rolling) Fabric Filter 0.015 lb/MMBtu

PacifiCorp

– Jim Bridger Unit 1 (530 MW) LNB + OFA 0.26 lb/MMBtu (30

- day rolling) ESP + FG C 0.030 lb/MMBtu

PacifiCorp

– Jim Bridger Unit 2 (530 MW) LNB + OFA 0.26 lb/MMBtu (30

- day rolling) ESP + FGC 0.030 lb/MMBtu

PacifiCorp

– Jim Bridger Unit 3 (530 MW) LNB + OFA 0.26 lb/MMBtu (30

- day rolling) ESP + FGC 0.030 lb/MMBtu

PacifiCorp

– Jim Bridger Unit 4 (530 MW) LNB + OFA 0.26 lb/MMBtu (30

- day rolling) ESP + FGC 0.030 lb/MMBtu

PacifiCorp

– Naughton Unit 1 (160 MW) LNB + OFA 0.26 lb/MMBtu (30

- day rolling) ESP + FGC 0.040 lb/MMBtu

PacifiCorp

– Naughton Unit 2 (210 MW) LNB + OFA 0.26 lb/MMBtu (30

- day rolling) ESP + FGC 0.040 lb/MMBtu

PacifiCorp

– Naughton Unit 3 (330 MW) LNB + OFA +

SCR 0.07 lb/MMBtu (30

- day rolling) Fabric Filter 0.015 lb/MMBtu

PacifiCorp

– Wyodak Unit 1 (335 MW) LNB + OFA 0.23 lb/MMBtu (30

- day rolling) Fabri c Filter 0.0 15 lb/MMBtu

(1) Filterable portion only; (2) These emission limits reflect condition 7c in the Settlement Agreement between DEQ/AQD and Basin Electric, EQC Docket No. 10

- 2802.

ESP = electrostatic precipitator; FGC = flue gas conditioning; LNB = low NO

x burners ; n/a = not subject to BART ; OFA = overfire air; SCR = selective catalytic reduction; SOFA = separated overfire air95 I. The Five

- Factor Analysis 308(e)(1)(ii)(A) - The determination of BART must be based on an analysis of the best sy stem of continuous emission control technology available and associated emission reductions achievable for each BART -eligible source that is subject to BART within the State. In this analysis, the State must take into consideration the technology available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, any pollution control equipment in use at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

Details of how each of these factors is taken into consideration during the BART determination process are found below in the Facility Analysis section.

II. Compliance With Appendix Y 308(e)(1)(i i)(B) - The determination of BART for fossil-fuel fired power plants having a total generating capacity greater than 750 megawatts must be made pursuant to the guidelines in appendix Y of this part (Guidelines for BART Determinations Under the Regional Haz e Rule).

EPA’s guidelines are only mandatory with respect to plants greater than 750 megawatts (see 70 Fed. Reg. at 39108, 39131). EPA does not require that the guidelines be followed for other source types (see id. ). In fact, EPA concluded that it “would not be appropriate for EPA to require states to use the guidelines in making BART determinations for other categories of sources” ( id . at 39108). States thus “retain the discretion to adopt approaches that differ from the guidelines” ( id . at 39158). The following fossil- fuel fired power plants have a total generating capacity greater than 750 megawatts:

Basin Electric Power Cooperative - Laramie River (1,650 MW) PacifiCorp - Dave Johnston (772 MW) PacifiCorp - Jim Bridger (2,120 MW)

EPA’s guidelines in Appendix Y were followed for the three facilities listed above. Details of how the guidelines were followed are found in the Facility Analysis section below.

III. Expeditious Installation and Operation of BART 308(e)(1)(iv) - A requirement that each source subject to BART be required to install and operate BART as expeditiously as practicable, but in no event later than 5 years after approval of the implementation plan revision.

This requirement is addressed in Wyoming’s BART R ule and compliance with this requirement is discussed in the specific Facility Analysis for each source below

.

IV. Proper Maintenance and Operation of Control Equipment 308(e)(1)(v) - A requirement that each source subject to BART maintain the control equipment required by this subpart and establish procedures to ensure such equipment is properly operated

and maintained.96 This requirement is addressed in Wyoming’s BART Rule and compliance with this requirement

is discussed in Section V

.

V. Monitoring and Recordkeeping Require ments

Startup Notification: The owner or operator shall furnish the Administrator written notification of: (i) the anticipated date of initial startup not more than 60 days or less than 30 days prior to such date, and; (ii) the actual date of initial st artup within 15 days after such date in accordance with Chapter 6, Section 2(i) of the WAQSR.

Chapter 6, Section 3 Operating Permit: The owner or operator shall modify their Operating Permit in accordance with Chapter 6, Section 9(e)(vi) and Chapter 6, Section 3 of the WAQSR.

Initial Performance Tests: The owner or operator shall conduct initial performance tests in accordance with Chapter 6, Section 2(j) of the WAQSR, within 30 days of achieving a maximum design rate but not later than 90 days followin g initial startup, and a written report of the results shall be submitted. If a maximum design rate is not achieved within 90 days of startup, the Air Quality Division Administrator may require testing be done at the rate achieved and again when

a maximum rate is achieved.

Periodic Particulate Performance Testing: Particulate testing shall be conducted annually, or more frequently as specified by the Air Quality Division Administrator following the test methods specified in this section.

Test Methods:

NO

x Emissions - Compliance with the NO

x 30-day rolling average shall be determined using a continuous emissions monitoring system (CEMS) certified in accordance with 40 CFR part 60 (Non- EGUs) or 40 CFR part 75 (EGUs).

PM/PM 10 Emissions

- Testing shall foll ow 40 CFR 60.46 and EPA Reference

Test Methods 1-4 and 5.

Prior to any testing, a test protocol shall be submitted to the Division for approval, at least 30 days prior to testing. Notification should be provided to the Division at least 15 days prior to any testing. Results of the tests shall be submitted to the Division office within 45 days of completing the tests.

NO

x CEM Requirements: At all times after the compliance deadline specified in Section 6.5, the owner/operator of each BART unit shall maintain, calibrate, and operate a CEMS in full compliance with the requirements found at 40 CFR part 60 (Non-EGUs) or 40 CFR part 75 (EGUs), to accurately measure NO

x , diluent (CO 2 or O 2 ), and stack gas volumetric flow rate

from each BART unit. The CEMS sha ll be used to determine compliance with the NO

x BART

emission limits for each BART unit.

BART Limits: The NO

x limits in terms of lb/MMBtu, lb/hr and tpy apply at all times, including periods of startup and shutdown. The PM/PM 10 limits in terms of lb/hr and tpy apply at all97 times, including periods of startup and shutdown. The PM/PM 10 limits in terms of lb/MMBtu apply at all times except during startup. Emissions in excess of the BART limits due to unavoidable equipment malfunction are not considered a violation if the event is covered under Chapter 1, Section 5 of the WAQSR. The burden of proof is on the owner or operator of the source to provide sufficient information to demonstrate that an unavoidable equipment

malfunction has occurred.

BART NO

x Lim its: lb/MMBtu and lb/hr shall be 30

- day rolling averages and the tpy shall be a calendar year total.

a. Exceedances of the NO

x limits shall be defined as follows:

i. Any 30- day rolling average which exceeds the lb/MMBtu NO

x limits as calculated using t he following formula:

n C

E n

h h

avg 

## ∑

= = 1 )(

Where:

E

avg = Weighted 30- day rolling average emission rate (lb/MMBtu).

C = 1- hour average emission rate (lb/MMBtu) for hour “ h ” calculated using valid data from the CEM equipment certified and operated in accordance with part 75 and the procedures in 40 CFR part 60, A ppendix A, Method 19. V alid data shall meet the requirements of WAQSR, Chapter 5, Section 2(j). Valid data shall not include data substituted using the missing data procedure in S ubpart D of part 75, nor shall the data have been bias adjusted according to the procedures of part 75.

n = The number of unit operating hours in the last 30 successive boiler operating days with valid emissions data meeting the requirements of WAQSR, Chapter 5, Section 2(j). A “boiler operating day” shall be defined as any 24

- hour period between 12:00 midnight and the following midnight during which any fuel is combusted at any time at the steam generating unit.

ii. Any 30- day rolling average which exceeds the l b/hr NO

x limits as calculated using the following formula:

n C

E n

h h

avg 

## ∑

= = 1 )(

Where:

E

avg = Weighted 30- day rolling average emission rate (lb/hr).98 C = 1- hour average emission rate (lb/hr) for hour “ h ” calculated using valid data (output concent ration and average hourly volumetric flowrate) from the CEM equipment certified and operated in accordance with part 75. Valid data shall meet the requirements of WAQSR, Chapter 5, Section 2(j). Valid data shall not include data substituted using the missing data procedure in Subpart D of part 75, nor shall the data have been bias adjusted according to the procedures of part 75.

n = The number of unit operating hours in the last 30 successive boiler operating days with valid emissions data meeting the requirements of WAQSR, Chapter 5, Section 2(j). A “boiler operating day” shall be defined as any 24

- hour period between 12:00 midnight and the following midnight during which any fuel is combusted at any time at the steam generating unit.

iii. Any 12 -month roll ing emission rate which exceeds the tpy NO

x limit as calculated using the following formula:



## ( )

000,2

1 

## ∑

= = h h C

E

Where:

C

= 1- hour average emission rate (lb/hr) for hour “ h ” calculated using data from the CEM equipment required by 40 CFR part 75. For monitoring data not meeting the requirements of WAQSR, Chapter 5, Section 2(j), Basin Electric shall provide substituted data for an emissions unit according to the missing data procedures of 40 CFR part 75 during any period of time that there is not monitoring data.

E

= 12- month rolling emission rate (tpy).

iv. Any calendar year total calculated using valid data (output concentration and average hourly volumetric flow rate) from the CEM equipment and operating data from the boiler which exceeds the tpy NO

x limit. Valid data shall meet the requirements of WAQSR Chapter 5, Section 2(j). For EGUs, the owner or operator shall use EPA’s Clean Air Markets reporting program to convert the monitoring system data to annual emissions. The owner or operator shall provide substituted data according to the missing data procedures of 40 CFR part 75 during any period of time that there is no monitoring data.

BART PM/PM 10 Limits: lb/MMBtu and lb/hr limits shall be a 1 -hour average based on the average of three performance tests. Compliance with lb/MMBtu and lb/hr shall be determined from the initial and annual performance tests. Annual emissions (tpy) shall be a calendar year total calculated using the lb/MMBtu performance test result and boiler operating data.99 Recor dkeeping and Reporting: The owner or operator shall comply with all reporting and recordkeeping requirements as specified in WAQSR Chapter 5, Section 2(g) and 40 CFR part 60, Subpart D. All excess emissions shall be reported using the procedures and repo rting format specified in WAQSR Chapter 5, Section 2(g). Records shall be maintained for a period of at least five (5) years and shall be made available to the Division upon request.

6.5 Facility Analysis

Note that the following discussions of BART determinations are based upon proposed BART permit conditions that are undergoing public review and comment. Following issuance of final BART permits as required by Chapter 6, Section 9 of the WAQSR, the State of Wyoming will supplement the SIP with revised descriptions of the BART determinations, if necessary.

6.5.1 FMC Wyoming Corp. - Granger Facility

The State of Wyoming per formed a refined CALPUFF visibility modeling analysis for the two

BART

- eligible units at the FMC Wyoming Granger F acility, and demonstrated that the predicted

98 th percentile impacts at Bridger WA and Fitzpatrick WA would be below 0.5 dv for all meteorological periods modeled. This modeling used higher- resolution meteorological data as compared to the data used by the Division for the initial screening modeling that identified the facility as “subject” to BART. A single source is exempt from BART if the modeled 98 th
percentile change is less than 0.5 dv at all Class I areas for each year modeled, in accordance

with Chapter 6, Sect ion 9(d)(i)(C) of the WAQSR. Therefore, the State of Wyoming has

determined that the two BART

- eligible units at the FMC Wyoming Granger F acility are not subject to BART.

6.5.2 FMC Wyoming Corp. - Green River
- Westvaco Facility

I. The Five

- Factor Anal ysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, (4) the remaining useful life of the source, and (5) the degree o f improvement in visibility (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM 10 emitted from two units at the Westvaco Facility

. The State of Wyoming concluded that a third unit at the facility , a gas -fired boiler, was not a significant contributor to regional haze and a BART determination was not made for that source.

For control of NO

x emissions, the State of Wyoming requires that FMC install and operate low

NO

x burners ( LNB ) with enhanced ov erfire air ( OFA ) as BART for boilers NS-1A and NS- 1B. The use of LNB and enhanced OFA will result in a 1,360-ton reduction in annual NO

x emission s from each boiler. LNB /OFA on boilers NS- 1A and NS

- 1B is cost effective

, with a n average cost
effectiveness of $304 per ton of NO

x removed for each unit over a twenty- year operational life. Combustion control using LNB /OFA does not require non- air quality environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and there is a minimal energy impact.100 For control of PM/ PM 10 emissions, the State of Wyoming requires that FMC utilize the existing

ESP s as BART f or boilers NS-1A and NS- 1B.

Visibility impacts were addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumulative 3

- year averaged visibility improvement from the baseline across Bridger WA and Fitzpatrick WA achieved with

LNB /OFA (based on the 98th percentile modeled results) was 0.2 Δdv from each of the two

boilers.

The State of Wyoming considers the BART

- determined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well mai ntained and operated in a manner consistent with good air pollution control practices for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Units Pollutant Control Type lb/MMBtu lb/hr tpy

NS -1A NO

x LNB/OFA 0.35 (30

- day rolli ng) 284.0 (30

- day rolling) 1244.0

PM/PM 10 (a) ESP 0.05 45.0 197.0

NS -1B NO

x LNB/OFA 0.35 (30

- day rolling) 284.0 (30

- day rolling) 1244.0

PM/PM 10 (a) ESP 0.05 45.0 197.0

(a) Filterable portion only

ESP = electrostatic precipitator

LNB = low NO

x burn ers OFA = overfire air

III. Expeditious Installation and Operation of BART

The State of Wyoming requires that FMC install and operate new LNB with enhanced overfire

air on boilers NS- 1A and NS

- 1B to achieve the BART emissions limits for NO

x . Installa tion of LNB and enhanced overfire air has been completed. LNB with OFA will continue to operate on boilers NS-1A and NS-1B. The State of Wyoming requires that FMC continue the use of the existing ESPs on boilers NS-1A and NS- 1B to achieve the BART emissi ons limits for PM/PM 10

. Initial performance tests for NO

x and PM/PM 10 have been completed for both boilers. NO

x and

PM/PM 10 compliance deadlines for both boilers was on or before October 17, 2009.

IV. Proper Maintenance and Operation of Control Equipment

The State of Wyoming requires that FMC follow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

6.5.3 General Chemical - Green River Works

I. The Five

- Factor Analysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, (4) the101 remaining useful life of the source, and (5) the degree of impr ovement in visibility (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM 10 emitted from the two boilers at Green River Works

.

For control of NO

x emissions, the State of Wyoming requires that General Chemical install and

operate LNB and SOFA or an equivalent performing control technology as BART for boilers C

and D. The use of LNB and SOFA will result in a 512-ton reduction from ba seline for Boiler C

and a 737-ton reduction from baseline for Boil er D. LNB and SOFA on boilers C and D is cost
effective

, with a n average cost effectiveness of $ 1,280-1,480 per ton of NO

x removed for each unit over a twenty-year operational life. Combustion control using LNB and OFA does not require non- air quality en vironmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and there is a minimal energy impact. Affording General Chemical the option to install an equivalent performing control technology does not change the basis of the BART

determ ination as the BART determination is made based on currently available controls (e.g., existing LNB with new SOFA, SNCR, SCR), which were all deemed reasonable. Allowing the company to install an equivalent performing technology provides additional flexib ility to control emissions to the specified BART levels, presumably in the most cost- effective manner.

For control of PM/ PM 10 emissions, the State of Wyoming requires that General Chemical utilize the existing ESP s as BART f or boilers C and D.

Visibility impacts were addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumulative 3

- year averaged visibility improvement from the baseline across Bridger WA and Fitzpa trick WA achieved with

LNB and OFA (based on the 98th percentile modeled results) was 0.41 Δdv from the two boilers.

The State of Wyoming considers the BART

- determined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Unit s Pollutant Control Type lb/MMBtu lb/hr tpy

C NO

x LNB/ S OFA or equivalent technology 0.28 (30

- day rolling) 149.5 (30

- day rolling) 654.9

PM/PM 10 (a) ESP 0.09 50 219.0

D NO

x LNB/ S OFA or equivalent technology 0.28 (30

- day rolling) 246.4 (30

- day rolling) 1,079.2

PM/PM 10 (a) ESP 0.09 80 350.4

(a) Filterable portion only

ESP = electrostatic precipitator

LNB = low NO

x burners

S OFA = separated overfire air102 III. Expeditious Installation and Operation of BART

The State of Wyoming requires that Genera l Chemical install and operate low NO

x burners with

S OFA or equivalent performing technology on boilers C and D, in accordance with the Division’s BART determination, and conduct the required initial performance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan revision

. The State of Wyoming requires that General Chemical continue the use of the existing ESPs on boilers C and D to achieve the BART

emissions limi ts. Initial performance tests for PM/PM 10 have been completed for both boilers.

The PM/PM 10 compliance deadline for both boilers was on or before November 11, 2009.

IV. Proper Maintenance and Operation of Control Equipment

The State of Wyoming require s that General Chemical follow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

6.5.4 PacifiCorp - Jim Bridger Power Plant

I. The Five

- Factor Analysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibili ty (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM/PM 10 emitted from the four units subject to BART at the Jim Bridger Power Plant. In addition to the five-factor analysis, the Division also considered the unique situation PacifiCorp is in since they own and operate 19 coal-fired generating units in the West. The Division believes that the size of PacifiCorp’s fleet of coal -fired units presents unique challenges when reviewing costs, timing o f installations, customer needs, and state regulatory commission requirements. Information has been supplied by PacifiCorp elaborating on additional factors to be considered in PacifiCorp’s BART determination (see “PacifiCorp’s Emissions Reductions

Plan” in Chapter 6 of the Wyoming TSD).

For control of NO

x emissions, the State of Wyoming requires that PacifiCorp install and operate LNB with separated OFA as BART for Units 1 through 4. Annual NO

x emission reductions

from LNB with separated OFA on Unit s 1, 3, and 4 are 4,493 tons per unit for a total annual reduction at the Jim Bridger Power Plant of 13,479 tons per year . There are no NO

x reductions

from Unit 2 as LNB separated OFA is baseline for the unit.

LNB with separated OFA on Units 1, 3, and 4 is c ost effective

, with a n average cost
effectiveness of $255 per ton of NO

x removed for each unit over a twenty- year operational life.

LNB with separated OFA on Unit 2 did not require any additional capital cost or annual O&M

cost. Combustion control using LNB with separated OFA does not require non- air quality environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and there is a minimal energy impact.103 For control of PM/ PM 10 emissions, the State of Wyoming requires that PacifiCorp utilize the existing electrostatic precipitators ( ESP s) with the addition of flue gas conditioning ( FGC ) as BART f or Units 1-4. The control technology is cost effective for each unit, with costs per ton removed of $1,544 for Unit 1, $526 for Unit 2, an d $857 for Unit 3. Unit 4 d oes not require additional capital cost. No negative non- air environmental impacts are anticipated from the use

of the existing ESPs with FGC.

Visibility impacts were addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumulative 3

- year averaged

98 th percentile visibility improvement from the baseline across the three Class I areas (Bridger, Fitzpatrick, and Mt. Zirkel wilderness areas) achieved with LNB with separated OFA, upgraded wet FGD, and FGC for enhanced ESP control was 1.070 Δdv from Unit 1, 0.199 Δdv from Unit 2, 1.068 Δdv from Unit 3, and 0.892 Δdv from Unit 4. While the visibility improvement

attributable to the installation of FGC on existing ESPs can’t be directly determined from the visibility modeling, the Division does not anticipate the contribution from PM to be significant when compared to the contributions from NO

x and SO 2

.

The State of Wyoming considers the BART

- det ermined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well maintained and operated in a manner consistent with good air pollution control pract ices for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Units Pollutant Control Type lb/MMBtu lb/hr tpy

1, 2, 3, & 4 NO

x LNB/OFA 0.26 (30

- day rolling) 1,560 (30

- day rolling) 6,833

1, 2, 3, & 4 PM/PM 10 (a) ESP + FGC 0.030 180 788

(a) Filterable portion only

ESP = electrostatic precipitator

FGC = flue gas conditioning

LNB = low NO

x burners

OFA = overfire air

III. Expeditious Installation and Operation of BART

The State of Wyoming requires that PacifiCorp install and operate new LNB with separated OFA on Unit 1, in accordance with the Division’s BART determination, and conduct the required initial performance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA ap proval of the state implementation plan revision. Installation of LNB and separated OFA has been completed and initial performance tests have been completed on Units 2, 3, and 4. The NO

x compliance deadline for Units 2-4 was on or before March 31,

2010. With respect to particulate matter, the State of Wyoming requires that PacifiCorp continue the use of the existing ESPs on Units 1 through 4 with FGC to achieve the BART emissions

limits. Initial performance tests have been conducted and the PM/PM 10 comp liance deadline for

Units 1 -4 was on or before March 31, 2010.104 IV. Proper Maintenance and Operation of Control Equipment

The State of Wyoming requires that PacifiCorp conduct i nitial NO

x performance tests on Unit 1,

after the installation of LNB and se parated OFA, within 30 days of achieving a maximum design

rate

, but not later than 90 days following initial start -up. If a maximum design rate is not achieved within 90 days of start-up, the AQD Administrator may require testing be done at the rate achieved and again when a maximum rate is achieved. A test protocol shall be submitted for Division approval prior to testing and a written report of the test results shall be submitted to the

Division . Testing required by the WAQSR Chapter 6, Section 3 opera ting permit may be submitted to satisfy the testing required.

The State of Wyoming requires that PacifiCorp follow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

6.5.5 Pa cifiCorp - Dave Johnston Power Plant

I. The Five

- Factor Analysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibility (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM 10 emitted from the two units subject to BART at the Da ve Johnston Power Plant.

For control of NO

x emissions, the State of Wyoming requires that PacifiCorp install and operate

LNB with advanced OFA as BART for Units 3 and 4 . The State of Wyoming will require a NO

x control level of 0.28 lb/MMBtu on a 30- day r olling average, below EPA’s applicable presumptive limit of 0.45 lb/MMBtu for cell- fir ed boilers burning subbituminous coal, for Unit

3. For Unit 4, the State of Wyoming will require a NO

x control level of 0.15 lb/MMBtu on a 30- day rolling average, equal to EPA’s applicable presumptive limit for tangential

- fired boilers burning subbituminous coal. Annual NO

x emission reductions from LNB with advanced OFA

on Unit 3 and 4 are 2,723 tons and 6,142 tons, respectively.

LNB with advanced OFA on Units 3 and 4 is cost effective , with an average cost effectiveness of $648 per ton of NO

x removed for Unit 3 and $137 per ton for Unit 4. Combustion control using LNB with advanced OFA does not require non-air quality environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and there is a minimal energy impact.

For control of PM/ PM 10 emissions, the State of Wyoming requires that PacifiCorp install and

operat e new full

- scale fabric filter s on Units 3 and 4 to meet corresponding BART emission limits on a continuous basis. When considering all the factors above and beyond the benefits associated with regional haze which include the existing precipitator’s current condition and performance and end of life issues, the ability of the current electr ostatic precipitator to meet anESP BART rate of 0.23 lb/MMBtu on a continuous basis and the enhanced mercury removal cobenefits the baghouse provides, the Wyoming Air Quality Division has determined that the costs

associated with the installation of a ne w full

- scale fabric filter are reasonable. A full

- scale fabric105 filter is the most stringent PM/PM 10 control technology and therefore the Division accepts it as BART. The Division considers the installation and operation of the BART- determined PM/PM 10

con trols of a new full- scale fabric filter on Unit 3 at Dave Johnston, as recently permitted in Air Quality Permit MD -5098, to meet the requirements of BART.

When considering all the factors above and beyond the benefits associated with regional haze which include the existing venturi scrubber’s current condition and performance and end of life issues, the ability of the current venturi scrubber to meet a venturi scrubber BART rate of 0.21 lb/MMBtu on a continuous basis and the enhanced mercury removal co-benefits the baghouse provides, the Wyoming Air Quality Division has determined that the costs associated with the

installation of a new full

- scale fabric filter are reasonable. A full

- scale fabric filter is the most stringent PM/PM 10 control technology and therefore the Division accepts it as BART. The Division considers the installation and operation of the BART- determined PM/PM 10 controls of a

new full- scale fabric filter on Unit 4 at Dave Johnston, as recently permitted in Air Quality

Permit MD -5098, to meet the requirements of BART.

V isibility impacts were addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumulative 3

- year averaged

98 th percentile visibility impr ovement from baseline, summed across all four Class I areas (Badlands and Wind Cave national parks, and Mt. Zirkel and Rawah wilderness areas) and achieved with LNB with advanced OFA, dry FGD, and a new full- scale fabric filter

, was 3.558

Δdv from Unit 3 and 1.963 Δdv from Unit 4.

The State of Wyoming considers the BART

- determined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well maintained an d operated in a manner consistent with good air pollution control practices for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Unit Pollutant Control Type lb/MMBtu lb/hr tpy

3 NO

x LNB/OFA 0.28 (30

- day rolling) 784 (30

- da y rolling) 3,434

PM/PM 10 (a) Fabric Filter 0.015 42.1 184

4 NO

x LNB/OFA 0.15 (30

- day rolling) 615 (30

- day rolling) 2,694

PM/PM 10 (a) Fabric Filter 0.015 61.5 269

(a) Filterable portion only

LNB = low NO

x burners

OFA = overfire air

III. Expedit ious Installation and Operation of BART

The State of Wyoming requires that PacifiCorp install and operate new low NO

x burners with advanced OFA on Units 3 and 4, in accordance with the Division’s BART determination, and conduct the required initial perfo rmance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan

revision . The State of Wyoming requires that PacifiCorp install new full

- scale fabric filters on106 Units 3 and 4, in accordance with the Division’s BART determination, and conduct the initial performance tests required to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan r evision.

IV. Proper Maintenance and Operation of Control Equipment

The State of Wyoming requires that PacifiCorp follow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

6.5.6 PacifiCorp - Naughton Power Plant

I. The Five

- Factor Analysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, ( 4) the remaining useful life of the source, and (5) the degree of improvement in visibility (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM 10 emitted from the three units subject to BART at th e Naughton Power Plant.

For control of NO

x emissions, the State of Wyoming requires that PacifiCorp install and operate

LNB with advanced OFA as BART for Units 1 and 2, and tune the existing LNB / OFA system on
Unit 3 and instal l SCR . Annual NO

x emission r eductions from baseline for L NB with advanced

OFA on Unit s 1 and 2 are 2,334 and 2,649 tons, respectively. Annual NO

x emission reductions from baseline achieved by tuning the existing LNB / OFA and installing SCR on Unit 3 are 5,542

tons.

LNB with advanced OFA on Units 1 and 2 is cost effective

, with a n average cost effectiveness of $426 and $357, respectively, per ton of NO

x removed for each unit over a twenty- year operational life. Combustion control using LNB with advanced OFA for Units 1 and 2 does not require non- air quality environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and there is a minimal energy impact. Th e cost effectiveness of tuning the existing LNB with OFA and installing SCR on Unit 3 was reasonable, with a value of $2,830 per ton of NO

x removed.

For control of PM/ PM 10 emissions, the State of Wyoming requires that PacifiCorp utilize the existing ESP s and add F GC as BART f or Units 1 and 2. The control technology is cost effective for each unit, with costs per ton removed of $1,721 for Unit 1 and $949 for Unit 2. No negative

non- air environmental impacts are anticipated from the use of existing ESPs with FGC. For

control of PM/ PM 10 emissions from Unit 3, the State of Wyoming requires that PacifiCorp install and operate a new, full

- scale fabric filter to meet a corresponding BART emission limit on a continuous basis. When considering all the factors above and beyond the benefits associated with regional haze which include the existing precipitator’s curren t condition and performance

and end-of- life issues, the ability of the current electrostatic precipitator to meet an ESP BART rate of 0.04 lb/MMBtu on a continuous basis, the enhanced mercury removal co- benefits the baghouse provides, and the reduced ash loading on the SO 2 scrubber which will enhance the scrubber performance, the Wyoming Air Quality Division has determined that the costs107 associated with the installation of a new full

- scale fabric filter are reasonable. A full

- scale fabric filter is the most stringent PM/PM 10 control technology and therefore the Division accepts it as BART. The Division considers the installation and operation of the BART- determined PM/PM 10 controls of a new full- scale fabric filter on Unit 3 to meet the statutory requireme nts of BART.

Visibility impacts were addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumulative 3

- year averaged

98 th percentile visibility improvement from the b aseline across Bridger WA and Fitzpatrick WA

achieved with LNB with advanced OFA, wet FGD, and FGC for enhanced ESP control was 1.716 Δdv from Unit 1 and 1.934 Δdv from Unit 2. While the visibility improvement attributable to the installation of FGC on existing ESPs can’t be directly determined from the visibility modeling, the Division does not anticipate the PM contribution to be significant when compared to the NO

x and SO 2 contributions. For Unit 3, t he cumulative 3

- year averaged 98 th
percentile visibility improvement from the baseline summed across both Class I areas achieved by tuning the existing LNB with OFA, wet FGD and install ing a new full- scale fabric filter, was

0.826 Δdv. The installation of SCR on U nit 3 produces an additional 1.023 Δdv in cumulative

, 3- year averaged 98 th percentile modeled visibility improvement across the two Class I areas.

The State of Wyoming considers the BART

- deter mined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well maintained and operated in a manner consistent with good air pollution control practic es for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Units Pollutant Control Type lb/MMBtu lb/hr tpy

1 NO

x LNB/OFA 0.26 (30

- day rolling) 481 (30

- day rolling) 2,107

PM/PM 10 (a) ESP + FGC 0.040 74 324

2 NO

x LNB/OFA 0.26 (30

- day rolling) 624 (30

- day rolling) 2,733

PM/PM 10 (a) ESP + FGC 0.040 96 421

3 NO

x Tune LNB/OFA + SCR 0.07 (30

- day rolling) 259 (30

- day rolling) 1,134

PM/PM 10 (a) Fabric Filter 0.015 56 243

(a) Filterable portion only

ESP = electrostatic preci pitator

FGC = flue gas conditioning

LNB = low NO

x burners

OFA = overfire air

III. Expeditious Installation and Operation of BART

The State of Wyoming requires that PacifiCorp install and operate new low NO

x bu rners with

advanced OFA and install flu e gas conditioning on the existing ESPs on Units 1 and 2, in accordance with the Division’s BART determination, and conduct the required performance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA

app roval of the state implementation plan revision

.108 The State of Wyoming requires that PacifiCorp shall tune the existing low NO

x burners with

OFA and install selective catalytic reduction and a full

- scale fabric filter on Unit 3, in accordance

with the Division’s BART determination to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan

revision.

IV. Proper Maintenance and Operation of Control Equipment

The State of Wyomi ng requires that PacifiCorp follow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

6.5.7 PacifiCorp - Wyodak Power Plant

I. The Five

- Factor Analysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibilit y (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM 10 emitted from the single unit subject to BART at the Wyodak Power Plant.

For control of NO

x emissions, the State of Wyoming requires that PacifiCorp install and operate

LNB with advanced OFA as BART for Unit 1 . Annual NO

x emission reductions from baseline

with LNB with advanced OFA on Unit 1 are 1,483 tons. LNB with advanced OFA on Unit 1 is

cost effective

, with a n average cost effectiveness of $881 per ton of NO

x removed over a twentyyear operational life. Combustion control using LNB with advanced OFA does not require nonair quality environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and

there is a minimal e nergy impact.

For control of PM/ PM 10 emissions from Unit 1, the State of Wyoming requires that PacifiCorp

install and operate a new
, full

- scale fabric filter to meet a corresponding BART emission limit on a continuous basis. When considering all the factors above and beyond the benefits associated with regional haze which include the existing precipitator’s current condition and performance and end of life issues, the ability of the current electrostatic precipitator to meet an ESP BART rate of 0.10 lb/MMBtu on a continuous basis, and the enhanced mercury removal co-benefits the baghouse provides, the Wyoming Air Quality Division has determined that the costs associated

with the installation of a new full

- scale fabric filter are reasonable. A full

- scale fabric filter is the most stringent PM/PM 10 control technology and therefore the Division accepts it as BART. The Division considers the installation and operation of the BART- determined PM/PM 10 controls of a

new full- scale fabric filter at Wyodak, as re cently permitted under Air Quality Permit MD -7487, to meet the requirements of BART.

V isibility impacts were addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumu lative 3

- year averaged

98 th percentile visibility improvement from the baseline summed across both Class I areas (Badlands and Wind Cave national parks) achieved with LNB with advanced OFA, upgrading

the dry FGD, and a new full- scale fabric filter was 0.996 Δdv.109 The State of Wyoming considers the BART

- determined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Unit Pollutant Control Type lb/MMBtu lb/hr tpy

1 NO

x LNB/OFA 0.23 (30

- day rolling) 1,081.0 (30

- day rolling) 4,735

PM/PM 10 (a) Fabric Filter 0.015 71.0 309

(a) Filterable portion only

LNB = low NO

x burners

OFA = overfire air

III. Expeditious Installation and Operation of BART

The State of Wyoming requires that PacifiCorp install new low NO

x burners with advan ced OFA and a new full-scale fabric filter on Unit 1, in accordance with the Division’s BART determination, and conduct the initial performance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan revision

.

IV. Proper Maintenance and Operation of Control Equipment

The State of Wyoming requires that PacifiCorp follow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

6.5.8 Basin Electric Power Cooperative - Laramie River Station

The Air Quality Division issued a BART permit for Basin Electric Power Cooperative
- Laramie River Station on December 31, 2009 under Permit No. MD-6047. A summary of the Division’s five -factor analysis performed to support the BART permit issued on December 31, 2009 is included below. The detailed five- factor analysis is included in Attachment A of this

SIP.

I. The Five

- Factor Analysis

After considering (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any pollution equipment in use or in existence at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visib ility (all five statutory factors) from each proposed control technology, the Division determined BART for

NO

x and PM 10 emitted from the three units at the Laramie River Station.

For control of NO

x emissions, the State of Wyoming requires that Basin Elect ric install new LNB

with OFA as BART for Units 1 through 3. Annual NO

x emission reductions from new LNB110 with OFA on Units 1, 2, and 3 are 1,862-1,910 tons per unit for a total annual reduction of 5,645

tons.

LNB with separated OFA on Units 1 through 3 is cost effective

, with a n average cost
effectiveness of $2,036-$2,088 per ton of NO

x removed for each unit over a twenty- year operational life. Combustion control using LNB with OFA does not require non- air quality environmental mitigation for the use of chemical reagents (i.e., ammonia or urea) and there is a minimal energy impact.

For control of PM/ PM 10 emissions, the State of Wyoming requires that Basin Electric utilize the existing ESP s as BART f or Units 1 through 3. The cost of compliance for the sole technicallyfeasible control option, a retrofit fabric filter on the Unit 3 ESP, is not reasonable over a twentyy ear operational life. No negative non- air environmental impacts are anticipated from use of the existing ESPs.

Visibility impacts we re addressed in a comprehensive visibility modeling analysis covering three visibility impairing pollutants and associated control options. The cumulative 3

- year averaged visibility improvement from the baseline across Wind Cave NP and Badlands NP achieved with

new LNB with OFA at the 30 -day limit of 0.23 lb/MMBtu (based on the 98th percentile modeled results) was 0.14 Δdv from each of the three units. The expected visibility improvement over the course of a full annual period would be even greater due to the annual BA RT limit that is based

on 0.19 lb/MMBtu.

The State of Wyoming considers the BART

- determined permit limit to be equivalent to the control effectiveness of a control technology. The limit is based on continuous compliance when the control equipment is well maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions.

Unit

- by -unit BART determinations for NO

x and PM/PM 10 :

Units Pollutant Control Type lb/MMBtu lb/hr tpy

1 NO

x LNB/OFA 0.23 (30

- day rol ling) 1,348 (30

- day rolling) 5,343 (12

- month rolling)

PM/PM 10 (a) ESP 0.030 193 844

2 NO

x LNB/OFA 0.23 (30

- day rolling) 1,348 (30

- day rolling) 5,343 (12

- month rolling)

PM/PM 10 (a) ESP 0.030 193 844

3 NO

x LNB/OFA 0.23 (30

- day rolling) 1,386 (30

- day rolling) 5,493 (12

- month rolling)

PM/PM 10 (a) ESP 0.030 198 867

(a) Filterable portion only

ESP = electrostatic precipitator

LNB = low NO

x burners

OFA = overfire air

The performance/efficiency -based, 30-day rolling average emission rate of 0.23 l b/MMBtu is set to allow for continuous compliance with proper operation of the control equipment, while taking into account the normal operational variability that is typical for a boiler. The 30- day limits that111 are expressed in terms of mass emissions (l b/hr) are based on 0.21 lb/MMBtu. Because reduced steam loads on a boiler can result in periods of increased emissions in terms of lb/MMBtu but lower emissions in terms of lb/hr, the Division has chosen to set the dual 30- day limits, one set at 0.23 lb/MMBtu and one expressed in lb/hr based on 0.21 lb/MMBtu. For the 12-month rolling emission limits, the Division considered the ability of the source to maintain a lower emission rate over a longer time period and set the long

- term limit (expressed in tpy) b ased on 0.19

lb/MMBtu.

III. Expeditious Installation and Operation of BART

The State of Wyoming requires that Basin Electric install new low NO

x burners with separated OFA on Units 1 through 3, in accordance with the Division’s BART determination, and conduct the required initial performance tests to demonstrate compliance as expeditiously as practicable, but no later than five years after EPA approval of the state implementation plan revision.

The State of Wyoming requires that Basin Electric continu e the use of the existing ESPs on Units 1 through 3 to achieve the BART emissions limits. The PM/PM 10 compliance deadline was March 31, 2010.

IV. Proper Maintenance and Operation of Control Equipment

The State of Wyoming requires that Basin Electric fo llow the monitoring and recordkeeping requirements of Section 6.4 V. to ensure proper maintenance and operation of control equipment.

Subsequent NO

x BART Determinations

On March 8, 2010, Basin Electric Power Cooperative appealed the BART permit for the Laramie River Station before the Wyoming Environmental Quality Council (EQC). The Department of Environmental Quality entered into a settlement agreement on November 16, 2010 with Basin Electric Power Cooperative (Docket No. 10-2802). On December 8, 2010 , the Division held a State Implementation Plan (SIP) Hearing on Regional Haze. The SIP hearing was held in Cheyenne, Wyoming at the Laramie County Library, 2200 Pioneer Avenue. At that time, the Division collected public comment on the Regional Haze SIP revisions.

After carefully considering all comments on revisions to the State Implementation Plan to address Regional Haze, the Division has determined that the following table, taken from the Settlement Agreement Filed November 16, 2010 before the Wyomi ng EQC and incorporated into the EQC Order approving the Settlement, shall establish the BART limits for three units at Laramie River Station with respect to NO

x and NO

x only, and that these BART limits shall replace the BART limits for NO

x determined by t he Division in Permit MD -6047 issued on December 31, 2009. The Division has remodeled the emission limits established through this Settlement to determine the resulting visibility impacts. This impact analysis is included in

Attachment A.112 Effective up on completion of the initial performance tests to verify the emission levels below, emissions from Laramie River Station Units 1 through 3 shall not exceed the levels below.

The NO

x limits shall apply during all operating periods.

Pollutant lb/MMBtu lb/h r tpy

NO

x 0.21 (30

- day rolling) Unit 1: 1,220 Unit 2: 1,220 Unit 3: 1,254 (all 30

- day rolling) Unit 1: 4,780 Unit 2: 4,780 Unit 3: 4,914 (all 12

- month rolling)

Overall NO

x Reductions in Wyoming

In the State of Wyoming, significant additional NO

x reductions will be made at the completion of the BART process. The overall cumulative NO

x reductions from Wyoming BART sources over time are demonstrated in the figure below. If regional funding becomes available, future regional modeling will demonstra te the additional progress towards 2018 visibility goals.

Figure 6 .5.8-1. Additional Cumulative NO

x Reductions From Wyoming BART Sources113 

### CHAPTER 7

REASONABLE PROGRESS GOALS

7.1 Overview

The fundamental purpose of the Regional Haze Rule (RHR) is to restore visibility in all mandatory Class I areas across the United States to natural conditions by the year 2064. As required by the RHR, each state must submit a State Implementation Plan (SIP) that addresses

visibilit y reductions in Class I areas for the initial planning period of 2005-2018, with successive revisions occurring every ten years after 2018. In order to demonstrate incremental visibility improvement during the first planning period, the State of Wyoming was required to establish reasonable progress goals (RPGs) for the seven Class I areas within the state.

Reasonable progress goals listed in Section 7.5 of this chapter are used to gauge the progress that the State of Wyoming can reasonably make towa rds improving visibility to natural conditions in Class I areas within the state. Each Class I area RPG consists of two visibility values, expressed as deciviews (dv), that represent the most impaired visibility days (i.e., the average of the 20% most imp aired days over an entire year) and the least impaired visibility days (i.e., the average of the 20% least impaired days over an entire year).

While the reasonable progress goals are not enforceable, the control measures adopted by the State of Wyoming ar e enforceable. To determine if reasonable progress is being made in improving visibility, the S tate will need to collect and analyze air quality data and update the 5

- year visibility averages for the 20% worst visibility days and the 20% best visibility d ays and compare the 5

- year average with the baseline conditions (a fter 2018, the 5- year average will be compared to the impairment levels reported in the previous SIP revision). If t he control measures set by the S tate do not result in a reduction in visi bility impairment equal to or greater than the RPG for 2018, then the State of Wyoming can either revise its control strategies to meet the RPG or revise the RPG for the next planning period.

RPGs are non

- enforceable, interim goals, expressed in decivie ws, which represent interim visibility improvement in an effort to eventually achieve natural visibility conditions in Class I areas. When RPGs are established, they must provide for visibility improvement for the 20% worst visibility days and ensure that there is not a reduction in visibility for the least impaired days, calculated as the 20% best visibility days, through 2018. For states with multiple Class I areas, RPGs can be established separately for each one. The established goals must represent greater visibility improvement than what would result from the other requirements of the Clean Air Act (CAA).

States must revisit their reasonable progress goals in 2018, as discussed in Chapter 10 , by evaluating the progress towards natural conditions and the effectiveness of the long- term strategy for achieving the goals. If progress towards natural visibility conditions is unsatisfactory, the reasonable progress goals can be revised.114 7.2 Process for Establishing Reasonable Progress Goals

Several steps for establishing reasonable progress goals were outlined in the RHR and are discussed in the following subsections.

• Calculate/Estimate Baseline and Natural Visib ility Conditions

Baseline visibility conditions were determined by the Western Regi onal Air Partnership (WRAP) Technical Sup port System (TSS) using the Interagency Monitoring of Protected Visual Environments (IMPROVE) algorithm. The IMPROVE algorithm followed the established guidelines presented in the RHR. To determine baseline visibility conditions, the average degree of visibility (expressed as dv) for the 20% least impaired days and the 20% worst impaired days was calculated, using IMPROVE air quality monitoring data, for each calendar year from 2000

to 2004. The IMPROVE monitoring program collects speciated PM 2.5 , and PM 2.5 and PM 10 mass. IMPROVE is a nationwide network which began in 1988 and expanded significantly in 2000 in response to the EPA’s Regional Haze Rule (RHR). The Regional Haze Rule specifically requires data from t his program to be used by states and tribes to track progress in reducing haze. The annual values were then averaged over five years to determine the baseline visibility

condition values. Baseline visibility is discussed in detail in Chapter 2.

Natural conditions are an estimate of the amount of visibility impairment that would occur if no

human- caused visibility impairment existed. Natural conditions were determined by the WRAP through the Natural Haze Levels II Committee for the 20% worst visibility days and the 20% best visibility days using available monitoring data and the IMPROVE algorithm. The Natural Haze Levels II Committee was established in 2006 to review and refine the default approach. The committee included representatives from NOAA, NPS, Cooperative Institute for Research in the Atmosphere ( CIRA ), Regional Planning Organization s ( RPO s) and industry representatives, and other participants. The final report of the committee can be found at: http://wrapair.org/forums/aoh/meetings/060726den/NaturalHazeLevelsIIReport.pdf . Additional information about the baseline and natural visibility impairment calculations can be found in Chapter 13.

• Determine the Uniform Rate of Progress (URP)

The URP (also known as the glide slope), which was determined by the State of Wyoming for all mandatory Class I areas within the state, is the rate of visibility change necessary to achieve natural visibility conditions by the year 2064. The URP represents the slope between baseline visibility conditions in 2004 and natural visibility conditions in 2064. Using interpolation, the improvement necessary by 2018 to achieve natural visibility conditions in 2064 can be calcul ated

as shown in Table 7.2-1. The URP is discus sed in greater detail in Chapters 3 and 5.115 Table 7.2-1. 20% Best and Worst Days Baseline, Natural Conditions, and Uniform Rate of Progress Goal for Wyoming Class I Areas

IMPROVE

Monitor

Name Wyoming Class I Areas 20% Worst Days 20% Best Days

2000

- 04

Baseline

(dv) 2018

URP

Goal (dv) 2018

Reduction

Needed

(dv) 2064

Natural

Conditions (dv) Future Date for Reaching

Natural

Conditions at

Current Rate 2000

- 04

Baseline

(dv) 2064

Na tural

Conditions (dv)

YELL2 Yellowstone National Park

Grand Teton National Park

Teton Wilderness 11.8 10.5 1.3 6.4 2130 2.6 0.4

NOAB1 North Absaroka Wilderness

Washakie Wilderness 11.5 10.4 1.1 6.8 2136 2.0 0.6

BRID1 Bridger Wilderness Fitzpatrick Wilde rness 11.1 10.0 1.1 6.5 2165 2.1 0.3 (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

• Four Factor Analysis

In an effort to reduce visibility impairing air pollutants, emission control measures had to be evaluated. The four factor analysis process was established in the RHR and is discussed in detail in Section 7.3 of this chapter. Each emission control strategy, as required by the four factor analysis guideli nes, was evaluated based on 1) the cost of compliance, 2) time necessary for compliance, 3) the energy and non

- air quality environmental impacts of compliance, and 4) the remaining useful life of any existing source subject to such emission controls.

• Consultation With O ther States

According to the RHR, the State of Wyoming must consult with other states that may cause or contribute to visibility impairment in Wyoming Class I areas. For the State of Wyoming, consultations with other states contributing to visibility impairment in Class I area s were conducted through the WRAP. Additional information on the state consultations can be found in Chapter 11.

• Determination of Reasonable Progress Goals

Reasonable progress goals, when established, demonstrate the amount of visibility improvement the State of Wyoming believes to be feasible, based on the four factor analysis and Clean Air Act (CAA) requirements, during the first planning period. The reasonable progress goal may be the same, less stringent, or more stringent than the visibility improvement based on the URP. The reasonable progress goals, and the logic used to determine the goals, are discussed in Section s 7.5 and 7.6 of this chapter.

7.3 Four Factor Analysis Performed for Wyoming Sources

The four factor analysis, which is presented in the RHR, is a method for evaluating potential control strategies for facilities that are not eligible for Best Available Retrofit Technology (BART) or better

- than -BART programs. The analysis considers 1) the cost of compliance, 2) the time necessary for compliance, 3) environmental impacts of compliance, and 4) the remaining useful life of the facility.116 The WRAP hired EC/R Incorporated (EC/R), headquartered in Chapel Hill, North Carolina, to complete the four factor analysis. Control measures for NO

x and direct particulate matter

emission s were evaluated f or selected sources in Wyoming. A four factor analysis is not required for SO 2 since the State of Wyoming has addressed visibility impairment associated with this pollutant under the 309 SIP previously submitted to EPA.

7 .3.1 Detailed Description of the Four Factors

• Cost of Compliance

Both control costs and net annual costs were analyzed for all control measures identified by EC/R. Control costs cover direct and indirect capital costs. E xamples of direct capital expenses includes the costs associated with purchased equipment, construction, installation, instrumentation and process controls, ductwork and piping, electrical components, and structural and foundation components. Indirect capital expenses include costs such as engineering and design, contractor fees, startup and performance testing, contingency costs, and process

modifications.

Net annual costs include the expenses associated with the typical operation of the control equipment over a year. Annual costs include items such as the utility expenses, labor, waste disposal expenses, and amortized costs of the capital investment. All cost estimates calculated by EC/R were updated to 2007 dollars using the Marshall and Swift Equipment Cost Index or the Chemical Engineering Plant Cost Index, which are both published in the journal Chemical Engineering.

• Time Necessary for Compliance

Th e time necessary for compliance includes the time needed for the State of Wyoming to develop and imp lement reg ulations for emissions controls, as well as the time the sources require to procure the capital to purchase the emission control equipment, design and fabricate the equipment, and to install the emission controls. When a retrofit control device is required, the time necessary for compliance includes the time for capital procurement, device design, fabrication, and installation.

• Energy and O ther Non

- Air Quality Environmental Impacts

Emission control devices often require some form of energy inpu t to operate. To determine the energy requirements for a particular control device, the electricity needs, steam requirements, increased fuel requirements, and any additional energy inputs required were quantified. Only the direct energy requirements wer e considered; indirect energy needs, such as the amount of energy required to produce the fuel for the control device, were not analyzed. In addition, any impacts the control technologies had on other source processes, such as boiler efficiency, were not

evaluated.117 While the control devices reduce air pollution, they often produce waste. Environmental impacts of each control technology were analyzed by EC/R and included the waste generated, the wastewater generated, additional CO 2 produced, reduced acid deposition, and reduced nitrogen deposition. If available, the benefits from PM 2.5 and ozone reductions were also evaluated.

• Remaining Equipment Life at Source

The remaining equipment life of the source will impact the cost of emission control technolo gies if the expected life of the source is less than the lifetime of the pollution control device being considered. Therefore, if the remaining equipment life is less than the lifetime of the pollution control device, the capital cost of the pollution con trol device is amortized for the remaining life

of the emission source. To determine the annual cost of the emission control device if the expected life of the source is less than the expected life on the control device, the following equation can be used :

where:

A 1 = the annual cost of control for the shorter equipment life ($)

A 0 = the original annual cost estimate ($) C = the capital cost of installing the control equipment ($)

r = the interest rate (0.07) m = the expected remaining life of the emission source (years) n = the projected lifetime of the pollution control equipment

7.3.2 Source Selection Process for Four Factor Analysis

To select the sources that would undergo the required four factor analysis, emission data for sources in Wyoming had to first be collected. This was accomplished using the W RAP Emissions Data Management System ( EDMS ), which contains inventories from stationary sources, fires, area sources, on-road mobile sources, off-road mobile sources, windblown dust, and bioge nic sources across the state. After evaluating the emissions, it was determined that the primary emissions from anthropogenic sources, which are sources the S tate of Wyoming can regulate, were NO

x and SO 2 based on Tables 4.2-1 and 4.3-1, and Figures 5.2.1-1 through 5.2.1- 3 and 5.2.3-1 through 5.2.3-3 found in Chapters 4 and 5. Since sources of SO 2 were addressed in great detail in the previous 309 submittal, this screening process focuses on NO

x sources.

A basic screening technique, referred to as the Q uantity over Distance or “Q over D” analysis, was implemented by the State of Wyoming in order to select the sources to undergo the four factor analysis. There is no requirement to use this technique, but it has been employed by EPA

and other states to ro ughly determine which sources had the largest contributions of visibility impairing pollutants in Class I areas in Wyoming and surrounding states. It is a basic, intuitive

tool that allows the State to evaluate emissions from sources of concern. The sour ces of concern

in this first SIP were the large sources that were similar in magnitude to the sources covered under BART, but were not covered by the timeframe requirements of BART.118 The screening technique included sources when the following was met:

where Q represents the maximum emission rate, in tons per year, of the source and D is the

distance in kilometers to the nearest Class I area. A spreadsheet showing all of the sources with a Q/D g reater than 10 can be found in Chapter 7 of the Wyoming TSD. Three emission units
were identified in the state having and thereby selected to undergo the four factor

analysis.

7.3.3 PacifiCorp Dave Johnston Electric Generating Station

Two units, BW41 and BW42, at the Dave Johnston Electric Generating Station were selected for the four factor analysis in Wyoming. Both units are sub-bituminous coal- fired boilers capable of producing up to 114 megawatts (MW). Emissions are currently controlled with a cold

- side electrostatic precipitator (ESP).

Four possible emission control devices were identified and analyzed using the four factor analysis process for the boilers: low NO

x burners (LNB), low NO

x bu rners with overfire air (LNB w/ OFA), selective non- catalytic reduction (SNCR), and selective catalytic reduction (SCR). LNB technology reduces the amount of NO

x produced by reducing the flame temperature. The flame temperature is reduced by controlling the fuel and air mixing, which

creates a larger, bra nched flame. LNB w/OFA reduces NO

x emissions by separating the combustion air into primary and secondary flows. When the combustion air is separated, a more complete burn occurs and forms N 2 rather than NO

x . With SNCR, an aqueous reagent, typically

eith er ammonia or urea, is injected into the hot flue gas. The reagent reacts with the NO

x in the gas to form N 2 and water vapor. Similar to the SNCR technology, SCR technology uses

ammonia to reduce NO

x to N 2 and H 2 O. However, with SCR the NO

x in the flue gas reacts with the ammonia within a catalyst bed.

• Cost

The estimated capital costs, annual costs, and the cost effectiveness for the possible emission control devices at the Dave Johnston Electric Generating Station are shown in Table 7.3.3-1. The capital costs, which are expressed in terms of cost per MW size, were estimated based on a

cost estima te document produced by the EPA. 4 The capital costs for the Dave Johnston boilers had to be extrapolated from the cost estimate data provided by the EPA reference due to their large size. To determine the annual costs for the control devices, the capital costs were amortized over 20 years at an interest rate of 7% and then multiplied by a factor to account for operation and maintenance (O&M) costs. While SCR is expected to be far more efficient in controlling NO

x emissions than LNB or LNB w/ OFA, the estimated capital and annual costs are far higher than the costs associated with LNB or LNB w/ OFA. As shown in Table 7.3.3-1 , NO

x

4 EPA (2002), EPA Air Pollution Control Cost Manual

, 6th ed., EPA/452/B

- 02

- 001, U.S. EPA, Office of Air Qual ity Planning and Standards, RTP, NC, Section 5

- SO2 and Acid Gas Controls, pp 1

- 30 through 1

- 42, http://www.epa.gov/ttncatc1/products.html#cccinfo

.119 reductions using LNB or LNB w/O FA technology are far more cost effective than the SNCR and SCR technologies.

Table 7.3.3-1. Estimated Costs of Potential Emission Control Devices for Two Boilers at

the Dave John ston Electric Generation Station x

Cost Estimate s

Unit ID Control Technology Estimated

Control Efficiency (%) Estimated Capital Cost ($) Annual Cost ($/year) Cost Effectiveness ($/ton)

BW41 LNB 51 4,030,000 631,000 528

LNB w/ OFA 65 5,760,000 962,000 632

SNCR 40 4,160,000 2,490,000 2,659

SCR 80 11,500,000 3,390,000 1,810

BW42 LNB 51 4,030,000 631,000 538

LNB w/OFA 65 5,760,000 962,000 644

SNCR 40 4,160,000 2,490,000 2,709

SCR 80 11,500,000 3,390,000 1,844

x All values listed in Table 7.3.3

- 1 were obtained from the EC/R Incorporated report “Supplementary Information for

Four

- Factor Analyses for Selected Individual Facilities in Wyoming” and is included in Chapter 7 of the Wyoming

TSD.

• Time Necessary for Compliance

EC/R estimated that it would take nearly five and a half years for NO

x reduc tion strategies to become effective. It was determined that roughly two years would be necessary for the State of Wyoming to develop the necessary regulations to implement the selected control measures. EC/R estimated that it would take up to a year for the source to secure the capital necessary to purchase emission control devices. Based on estimates calculated by the Institute of Clean Air Companies (ICAC), approximately 18 months would be required for a company to design, fabricate, and install SCR or SNCR technology. Since there are two boilers being evaluated at Dave Johnston, an additional year may be required for staging the installation process.

• Energy and Non- Air Quality Environmental Impacts

The energy required to operate the emission control devices, including electricity and steam, and the waste produced by the emission control devices, such as solid waste and wastewater, are

shown in Table 7.3.3-2. As illustrated by the values in Table 7.3.3-2, none of the four technologies are expected to produce solid waste or wastewater. However, it should be noted that the SCR technology would periodically produce solid waste when the catalyst would need to

be changed. While LNB and LNB w/ OFA do not require steam, both SNCR and SCR require

steam to op erate. None of the technologies are expected to increase fuel consumption, though

LNB and LNB w/ OFA may reduce the fuel consumption due to optimized fuel combustion. In addition, LNB and LNB w/ OFA technologies need roughly 1/6 th the electricity required by

SNCR and 1/150 th the electricity required by SCR.120 Table 7.3.3-2. Estimated Energy and Non- Air Environmenta l Impacts of Potential

Emission Control Devices for Two Boilers at the Dave Johnston Electric

Generation Station x

Energy and Non

- Air Pollution Impacts

Unit ID Control Technology Estimated

Control Efficiency (%) Electricity Requirements (kW) Steam Requirements (lb/hr) Solid Waste Generated (ton/hr) Wastewater Produced (gal/min)

BW41 LNB 51 5.4 N/A N/A N/A

LNB w/ OFA 65 5.4 N/A N/A N/A

SNCR 40 31 439 N/A N/A

SCR 80 825 527 N/A N/A

BW42 LNB 51 5.4 N/A N/A N/A

LNB w/OFA 65 5.4 N/A N/A N/A

SNCR 40 31 431 N/A N/A

SCR 80 825 517 N/A N/A

x All values listed in Table 7.3.3

- 2 were obtained from the EC/R Incorporated report “Supplementary Information for

Four

- Factor Analyses for Selected Individual Facilities in Wyoming” and is included in Chapter 7 of the Wyoming

TSD.

• Remaining Life of the Boilers

The remaining life of the boilers at the Dave Johnston facility is not expected to have an impact on the cost of the control technologies.

• Dave Johnston Boilers BW41 and BW42 Four Factor Analysis Conclusion

As discussed previously, the LNB and LNB w/ OFA emission control technologies have a relatively low cost effectiveness value when compared with the SCR and SNCR technologies.

While the LNB and LNB w/ OFA estimated control efficiencies are between fifteen and twenty

nine percent lower than the SCR technology, the electricity requirements a re far lower for LNB

and LNB w/ OFA and neither requires steam. In addition SCR will produce solid waste every time the catalyst must be replaced. Therefore, based on the relatively low cost effectiveness, the reasonable control efficiency, possible reduction in fuel usage, low electricity requirements, and

the fact that solid waste and wastewater will not be produced, the LNB or LNB w/ OFA seem to be the most reasonable choice for the Dave Johnston Electric Generating Station boilers BW41 and BW42 based on the four factor analysis. The implementation of new control technologies on

the two boilers are discussed in further detail in Chapter 8 (Section 8.3.4), Long

- Term Strategy

.

7.3.4 Mountain Cement Company, Laramie Plant

At the Mountain Cement Company, Laramie Plant, only one unit was selected for the four factor analysis. The selected source, Cement Kiln #2, is a long dry kiln that can produce up to 1,500 tons of clinker per day.

Several options are available for the control of NO

x emissions and include both combustion and

NO

x removal controls. Combustion control options include direct- fired low NO

x burners (LNB),

indirect -fired LNB, and the CemStar process. NO

x removal control options include biosolid injection, LoTO

x TM , selective catalytic reduc tion (SCR), selective non- catalytic reduction (SNCR), and NO

x OUT. Low NO

x burners, whether installed on direct or indirect -fired kilns, reduce the flame turbulence, delay the fuel/air mixing, and establish fuel -rich zones for initial121 combustion. These three factors contribute to a reduction in thermal NO

x formation. The CemStar process introduces a small amount of steel slag to the kiln feed, which helps reduce the kiln operating temperature.

Biosolid injection uses wastewater treatment plant solids to reduce the kiln temperature required to produce clinker. The LoTO

x system (licensed by the BOC group), which injects ozone into the kiln, oxidizes NO

x and the resulting higher oxides of nitrogen are then removed by a wet

scrubber. SCR techno logy uses a catalyst such as tita nium dioxide or vanadium pentoxide to

convert NO

x to N 2 and H 2 O. SNCR, while similar to SCR, uses ammonia or urea to reduce NO

x formation, but does not require a catalyst. NO

x OUT is similar to SNCR and uses urea to convert

NO

x to nitrate and oxygen, but also has a proprietary additive that allows for a wider temperature range than the typical SNCR system.

• Cost

The estimated capital costs, annual costs, and the cost effectiveness for the possible emission control devices compiled by EC/R for the Mountain Cement Company, Laramie Plant are shown

in Table 7.3.4-1. Two options, SCR and LoTO

x TM have high control efficiencies that are predicted to be over 80%. However, no cost data was available for the LoTO

x TM system, making it impossible to evaluate its viability at the Laramie facility. SCR, while an effective control technology, has a cost effectiveness value that makes it cost prohibitive. Of the more cost effective options, SNCR using either urea or ammonia appears to be the most reasonable. SNCR provides a control efficiency similar to many of the other control technologies, but with a far

better cost effectiveness ratio.

Table 7.3.4-1. Estimated Costs of Potential Emission Control Devices for One Cement

Kiln at the Mountain Cement Company, Laramie Plant. x

Cost Estimates

Unit ID Control Technology Estimated

Control Efficiency (%) Pollutant

Controlled Estimated Capital Cost ($) Annual Cost ($/year) Cost Effectiveness ($/ton)

Kiln #2 LNB (in direct) 30

- 40 826,000 205,000 6,568

- 4,910 LNB (direct) 40 2,460,000 449,000 13,853 Biosolid Injection 50 474,000

- 127,000 1,324

NO

x OUT 35 NO

x 960,000 507,000 8,023

CemSTAR 20

- 60 Unknown Unknown Unknown

LoTO

x TM 80

- 90 Unknown Unknown Unknown

SCR 80 27,042,000 7,553,000 82,535 SNCR (urea) 35 Unknown Unknown 1,223 SNCR (ammonia) 35 Unknown Unknown 1,223

Fabric Filter 99 PM 10 5,261,000 4,451,000 262,489

Dry ESP 95

- 98 10,926,000 6,475,000 483,356

- 470,292

Fabric Filter 99 PM 2.5 5, 261,000 4,451,000 647,472

Dry ESP 95

- 98 10,926,000 6,475,000 1,242,915

– 1,160,054

x All values listed in Table 7 .3 .4 -1 were obtained from the EC/R Incorporated report “Supplementary Information for

Four

- Factor Analyses for Selected Individual Facilitie s in Wyoming” and is included in Chapter 7 of the Wyoming

TSD

.

• Time Necessary for Compliance

EC/R estimated that it could potentially take seven years to achieve emis sion reductions at the

Laramie f acility. This estimate includes the two years that will be necessary for the State of122 Wyoming to implement new regulations and the 1 year Mountain Cement will likely need to obtain the necessary capital for the purchase of new emission control technology. However, the total time necessary varies based on the control technology selected. For example, it is predicted

that one and a half years will be required to design, fabricate, and install SCR or SNCR technology, whi le over two and a half years will be requ ired to design, fabricate, and install

LoTO

x TM techn ology.

• Energy and Non- Air Quality Environmental Impacts

Table 7.3.4-2 details the energy requirements and waste produced by the potential emission control devices. Energy requirements include direct electricity and steam requirements, but do not include the energy required to produce the steam and electricity. None of the NO

x control technologies require additional fuel and some are even predicted to increase fuel efficiency. The options that are expected to increase fuel efficiency are indirect and d irect LNB, biosolid injection, and CemSTAR. However, there is no data indicating the expected fuel efficiency

increase. Without adequate data, it is not possible to determine if the increase in fuel efficiency is substantial and if there is any advantage to selecting an option that in creases fuel efficiency over an option that do es not increase fuel efficiency

.

Several of the NO

x control technologies are expected to require electricity and include both direct and indirect LNB, LoTO

x TM , and SNCR using urea or ammonia. Many of the technologies did not have sufficient data to quantify the energy requirements. This made it difficult to adequately evaluate the control options based on electricity requirements. However, some of the

NO

x control technologies are not predicted to have electricity requirements, which could make those options potentially more attractive. Those options include SCR, CemSTAR, NO

x OUT, and biosolid injection. None of the NO

x control technologies are expected to require steam.

Only a few of the NO

x control technologies are expected to produce waste, whether solid waste

or wastewater. LoTO

x is expected to produce both solid waste and wastewater, but estimates on the amount are not available at this time. Spent catalyst for SCR syst ems must be replaced periodically, which becomes solid waste. In addition, some fine particulate matter is produced by SCR systems that must be collected by a fabric filter or dry electrostatic precipitator (ESP). The particulate matter collected by a fa bric filter or dry ESP must be disposed of as solid waste; the presence of fine particles from the catalyst may require disposal as a hazardous waste.123 Table 7.3.4-2. Estimated Energy and Non- Air Environmenta l Impacts of Potential

Emission Control Devices for Kiln #2 at the Mountain Cement Company,

Laramie Plant x

Energy and Non

- Air Pollution Impacts (per ton of emission reduced)

Unit

ID Control Technology Potential

Emission

Reductions ( 1000 tons/yr) Pollutant

Controlled Additional

Fuel Requirements (%) Electricity Requirements

(kW

- hr ) Steam Requirements (lb/hr) Solid Waste

Generated

(ton/hr) Wastewater

Produced (gal/min)

Kiln

#2 LNB (indirect) 157

- 210

NO

x a 182 b b b LNB (direct) 210 a 182 b b b Biosolid Injection 262 a b b b b

NO

x OUT 183 b b b b b

CemSTAR 105

- 314 a b b b b

LoTO

x TM 419

- 472 b c b d d

SCR 419 b b b e b SNCR (urea) 183 b d b b b SNCR (ammonia) 183 b d b b b

Fabric Filter 37 PM 10 b d b 1 b

Dry ESP 15 b d b 1 b

Fabric Filter 36

- 37 PM 2.5 b d b 1 b

Dry ESP 14

- 15 b d b 1 b

a - The control technology is expected to improve fuel efficiency.

b

- Impact not expected.

c - Electricity requirements are expecte d to be high, but not enough data to quanti fy.

d

- Technology expected to have an impact, but insufficient data available to evaluate requirements.

e - Spent cataly st will have to be disposed of o n occasion.

x All values listed in Table 7.3.4

- 2 were obtained from the EC/R Incorporated report “Suppl ementary Information

for Four

- Factor Analyses for Selected Individual Facilities in Wyoming” and is included in Chapter 7 of the Wyoming TSD.

• Remaining Equipment Life

If Mountain Cement chooses to replace kiln #2, then the cost of the control technologie s for the currently operating kiln would likely be cost prohibitive.

If Mountain Cement decides not to replace kiln #2, then the remaining life of the kiln would likely be indefinite. Under this scenario, the lifetime of the selected control technology could be assumed to be equal to or less than the lifetime of the cement kiln. The capital cost of the control technology would not have to be amortized over the kiln lifetime, thus eliminating the impact of the remaining equipment life on the cost of the control technology.

The implementation of new control technologies on the cement kil n is discussed in Chapter 8 (Section 8.3.4), Long

- Term Strat egy

.

7.3.5 Oil and Gas Exploration and Production Field Operations

Oil and gas production, which is not li mited to just o ne area of Wyoming, is an important and critical component of th e state economy. S ources associated with oil and gas production emit

NO

x and PM. Sources include turbines, diesel engines, glycol dehydrat ors, amine treatment units, flares an d incinerators.

Emissions from large stationar y oil and gas sources in the WRAP region have been well quantified over the years, while smaller field and production sources are not as well understood.124 To better understand the emissions from all oil and gas sources across the region, the WRAP region instituted a three

- phase emission inventory project. Phase I, which was completed in 2005, was an emission inventory project that estimated regional emissions from oil and gas field operations for the first time. Phase II, completed in late 2007, was an effort to more fully characterize the oil and gas field operations emissions. The WRAP inventory currently addresses only large stationary sources and a consistent reporting system for oil and gas emissions fo r WRAP member states has not yet been developed. Members of the Independent Petroleum Association of Mountain States (IPAMS) felt that still more improvement in the accuracy of

these emission estimates was needed . So, in late 2007, IPAMS initiated a Phas e III regional oil and gas emission inventory project funded by their organization. The project was undertaken in conjunction with the WRAP to assure that the products from Phase III were widely distributed

among non- industry stakeholders (state/local age ncies, tribal air programs, Federal Land Managers, environmental groups and EPA). Phase III results will not be ready for this SIP

review.

While inventory work has not been completed on the oil and gas industry, the WRAP did engage

EC/R to assist with th e four factor analysis for oil and gas.

EC/R evaluated control technologies for common emission sources in the oil and gas industry: reciprocating engines and turbines, process heaters, flares and incinerators, and sulfur recovery

un it s. For compressor e ngines and gas -fueled reciprocating engines, potential control options presented by EC/R include air

- fuel ratio controls (AFRC), ignition timing retard, low

- emission combustion (LEC) retrofit, selective catalytic reduc tion (SCR), selective non- catalytic re duction (SN CR), and replacement with electric motors. LEC retrofit technology requires modification of the combustion system to increase the air

- to -fuel ratio, which creates very lean combustion conditions. Currently in Wyoming, many of the rich-burn eng ines associated wi th compressor

stations utilize SNCR in conjunction with AFRC, while lean-burn engines often utilize an oxidation catalyst to reduce emissions.

Regulating drill rig engines is problematic for states. Drill rig engines are, for the most p art, considered mobile sources and emission limits for mobile sources are set by the Federal government under Section 202 of the CAA. Several control options exist and include ignition timing retard, exhaust gas recirculation, SCR, replacement of Tier 2 e ngines with Tier 4 engines, and diesel oxidation catalyst.

Other common oil and gas exploration and production equipment also have emission control device options. Turbine emissions can be controlled by water or steam injection, low NO

x burners, SCR, and water or steam injection with SCR. NO

x emission control technologies for process heaters include LNB, ultra- low NO

x burners (ULNB), LNB with flue gas recirculation (FGR), SNCR, SCR, and LNB installed in conjunction with SCR. Glycol circulation rates on glycol dehydrators can be optimized to reduce VOC emissions. Control measures for flares, incinerators, and sulfur recovery units evaluated by EC/R control only SO 2 emissions and are not

addressed in this SIP.

NO

x emissions vary based on the equipment and fuel source. Emissions from individual natural

gas -fired turbines at production operations can be as high as 877 tons of NO

x per year (tpy),125 while emissions from individual natural gas turbines at exploration operations can reach 131 tpy. Individual g as reciprocating engines have comparable NO

x emissions with up to 700 tpy at production operations and 210 tpy at exploration operations. Diesel engine emissions can approach 46 tpy for production operations and 10 tpy for exploration operations.

• Cost

Table 7.3.5-1 lists the various control technologies identified by EC/R for oil and gas field operations. Both the capital and annual costs for each technology is dependent on the engine size or on the process throughput. For several of the control technologies listed in Table 7.3.5-1, cost estimate ranges are provided. The lower end of the cost estimates represent the cost per unit for the larger units or higher production due to economy of scale, while the higher end of the cost estimates represent t he cost per unit for the smaller units or lower production.

Flares, incinerators, sulfur recovery units, and glycol dehydrators were not included because the control technology evaluated by EC/R for those sources were only applicable for SO 2 or VOCs,

wh ich are not addressed by this SIP.126 Table 7.3.5-1. Estimated Costs for Oil and Gas Exploration and Production Equipment x

Cost Estimates

Source Type Control Technology Estimated

Control Efficiency (%) Pollutant

Controlled Estimated Capital Cost

($/unit) Annual Cost ($/year/unit) Units Cost

Effectiveness ($/ton)

Compressor

Engines Air

- fuel ratio control (AFRC) 10

- 40 NO

x 5.3

- 42 0.9

- 6.8 hp 68

- 2,500

Ignition timing

retard 15

- 30 NO

x N/A 1-3 hp 42

– 1,200

LEC retrofit 80

- 90 NO

x 120

– 820 30

– 210 hp 320

– 2,500

SCR 90 NO

x 100

– 450 40

– 270 hp 870

– 31,000

SN CR 90

– 99 NO

x 17

– 35 3 – 6 hp 16

- 36

Replacement with

electric motors 100 NO

x 120

- 140 38

- 44 100

– 4,700

100 PM 10 hp >79,000

100 PM 2.5 >7 9,000

Drilling Rig Engines and

Other Engines Ignition timing

retard 15

– 30 NO

x 16

- 120 14

– 66 hp 1,000

– 2,200

Exhaust gas recirculation (EGR) 40 NO

x 100 26

– 67 hp 780

– 2,000

SCR 80

– 95 NO

x 100

– 2,000 40

– 1,200 hp 3,000

– 7,700

Replacement o f Tier 2 engines with

Tier 4 87 NO

x 125 20 hp 900

– 2,400

85 PM 10 25,000

– 68,000

85 PM 2.5 25,000

– 68,000

Diesel oxidation catalyst 25 PM 10 10 1.7 hp 1,400 25 PM 2.5

Turbines Water or steam injection 68

– 80 NO

x 4.4

– 16 2 – 5 1000 BT U 560

– 3,100

Low NO

x burners (LNB) 68

– 84 NO

x 8

– 22 2.7

– 8.5 1000 BTU 2,000

– 10,000

SCR 90 NO

x 13

– 34 5.1

– 13 1000 BTU 1,000

– 6,700

Water or steam injection with SCR 93

– 96 NO

x 13

– 34 5.1

– 13 1000 BTU 1,000

– 6,700

Process

Heaters LNB 40 NO

x 3.8

– 7.6 0.41

– 0.81 1000 BTU 2,100

– 2,800

Ultra

- Low NO

x Burners (ULNB) 75

– 85 NO

x 4.0

– 13 0.43

– 1.3 1000 BTU 1, 500

– 2,000

LNB and FGR 48 NO

x 16 1.7 1000 BTU 2,600

SNCR 60 NO

x 10

– 22 1.1

– 2.4 1000 BTU 4,700

– 5,200

SCR 70

– 90 NO

x 33

– 48 3.7

– 5.6 1000 BTU 2,900

– 6,700

LNB and SCR 70

– 90 NO

x 37

– 55 4

– 6.3 1000 BTU 2,900

– 6,300

x All values liste d in Table 7.3.5

- 1 were summarized from the EC/R Incorporated report “Sup plementary Information for Four Factor Analyses by WRAP States ” and is included in Chapter 7 of the Wyoming TSD.

Based on available State permitting data, some of the larger compressor engines in the state can approach 2,900 hp, while coal bed methane engines can be as small as 98 hp. Some of the emissions control technologies for compressor engines, such as SCR, can become quite costly based on the horsepower (hp) of the engine. This also holds true for other oil and gas exploration and production equipment depending on the engine size or production. Drilling rig engines can range from 550 hp for diesel engines up to 2,119 hp for natural gas engines, with 1,476 hp engines common in the field. Turbines are generally around 112 MMBtu/hr, though turbines can be as small as 0.4 MMBtu/hr or as large as 380 MMBtu/hr. P rocess heaters in Wyoming commonly range from 0.87 MM Btu /hr to 1.5 MM Btu /hr, with process heaters having a throughput of 0.75 MM Btu /hr being common in the state.

In the case of compressor engines, many facilities throughout the state have already installed control equipment. For lean burn engines, oxidation catalysts are commonly installed while

SN CR catalysts with AFRC are commonly installed for rich burn engines.127 • Time Necessary for Compliance

EC/R predicted that up to two years would potentially be required for Wyoming to develop the necessary regulations. It is estimated that companies would require a year to procure the necessary capital to purchase the control equipment. The time required to design, fabricate, and install control technologies vary based on the control technology selected and other factors. It is predicted that 13 months would be required for the design, fabrication, and installation of SCR or SNCR technology, though some regulators have found that the time required is closer to 18 months. If multiple sources at a facility are to be controlled, an additional 12 months may be required for staging the installation process.

The implementation of new control technologies for oil and gas operations is discussed in further

detail in Chapter 8 , Long

- Term Strategy

.

7.4 309 SIP and 309(g)

51.309(g) allows the State to demonstrate reasonable progress for Wyoming’s seven Class I areas by building upon and taking full credit for the strategies already adopted, and taking full

credit for the strategies already adopted for protecting the 16 Class I areas on the Colorado Plateau with a primary emphasis on controlling SO 2 and anthropogenic smoke. All of those strategies have been submitted to EPA under a 309 SIP. Furthermore, those strateg ies have been included in the WRAP regional modeling demonstration establishing expected visibility conditions on the most impaired and least impaired days for all of Wyoming’s Class I areas. A comparative review of Wyoming SO 2 source impact on the Colora do Plateau Class I areas and the Wyoming Class I areas shows that reductions in SO 2 have a much greater impact on Wyoming Class I areas than those on the Colorado Plateau. This Plan, which is submitted under 309(g), contains many additional measures focused on controlling NO

x and PM. The combined

SO 2 control strategies of t he 309 SIP and the 309(g) SIP, which have be en modeled by the WRAP, provide the basis for established reasonable progress goals in Wyoming’s Class I areas.

7.5 Setting Reasonable Prog ress Goals

Under Section 308(d)(1) of the Regional Haze Rule, states must “establish goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility conditions”

for each Class I area of the state. These RPGs must provide for an improvement in visibility for the most impaired visibility days, and ensure no degradation for the least impaired visibility days over the same period. The RPGs are interim goals that represent incremental visibility improvement over time, in this case out to the year 2018, to be compared to the 2018 UniformRate of Progress (URP) glide slope. Based on the steps outlined in Section 7.2 and the FourFactor Analysis in Section 7.3, the Division has established RPGs for each of Wyoming’s seven Class I areas, as described below. These RPGs are based primarily on results of the CMAQ modeling described in Section 5.1.2, and on the four- factor analysis on major source categories. These goals do not reflect additional improvements in visibility fr om controls that were not included in the 2018 WRAP modeling. It would be difficult to set goals lower than the anticipated target without additional modeling.128 Table 7.5-1 shows that for the 20% best days, the RPGs show an improvement over baseline conditions, and thus ensure no visibility degradation. For the 20% worst days, the RPGs are short of the 2018 URP, but can be justified based on the demonstration provided in Section 7.6.

Table 7.5-1. Reasonable Progress Goals for 20% Worst Days and 20% Best Days for Wyoming Class I Areas

Wyoming

Class I Area 20% Worst Days 20% Best Days

Baseline

Condition (dv) 2018

Uniform Progress

Goal (dv) 2018

Reasonable

Progress

Goal (dv) Baseline

Condition (dv) 2018

Reasonable

Progress

Goal (dv )

Yellowstone National Park

Grand Teton National Park

Teton Wilderness 11. 8 10.5 11 .2 2. 6 2.4

North Absaroka Wilderness

Washakie Wilderness 11. 5 10. 4 1 1.0 2.0 2.0

Bridger Wilderness Fitzpatrick Wilderness 11.1 10.0 1 0.6 2.1 2.0

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

7.6 Demonstration That the RPGs for 20 Percent Best and Worst Days are Reasonable

EPA guidance indicates that “States may establish an RPG that provides for greater, lesser o r equivalent visibility improvement as that described by the glidepath.” The 2018 RPGs identified

in T able 7.5-1 for 20 percent worst days show an improvement in visibility, although less than the 2018 URP. The Division believes that RPGs are reasonable based on the following factors:

1. Emissions from natural sources greatly affect the State’s ability to meet the 2018 deciview URP goal. The analysis in Chapters 4 and 5 of this P lan containing summaries of emissions data, source apportionment, and modeling shows the contribution from natural or nonanthropogenic sources, such as natural wildfire and windblown dust is the primary reason for not achieving the 2018 URP in Wyoming’s Class I areas. The S tate has little or no control over OC, EC, PM 2.5 , coarse P M and soil emissions associ ated with natural fire and windblown dust. Prolonged droughts in the West have resulted in

extensive wildfires and increased dust emissions. The idea of setting deciview URP goals was developed before the causes of haze in the West were well understood. The extensive technical analysis of the causes of ha ze conducted by the WRAP has led to a better understanding of the role of wildfire and dust in visibility impairment. As long as

there are wildfires in the Western United S tates, there will be significant impact to visibility in Class I areas and there is little states can do about it.

2. Emissions from sources outside the WRAP modeling domain (international emissions) also affect the State’s ability to meet the 2018 URP goal. The analysis in Chapter 5 of

this Plan containing monitoring and modeli ng results shows the emissions from

international sources are a significant contribu tor to sulfate and nitrate concentrations a t
the monitors in most Western Class I areas, including th ose in Wyoming. The S tate has little or no control over emissions coming from other countries in the world.129 3. Major reductions in SO 2 emission s established in the previously submitted Wyoming 309

SIP demonstrate the S tate’s commitment to reducing visibilit y impairment. Tremendous progress has alread y been made toward capping and controlling SO 2 emissions from major point sources from the four states that have elected to participate in the Western Backstop Trading Program, including Wyoming.

4. The largest po int source category of NO

x emis sions is coal-fired power plants. In Wyoming, significant reductions from these plants will be achieved through the implementation of BART levels established in this P lan, as well as additional redu ctions

committed to in the long- term strategy.

5. The second largest category of stationary sources in the West is oil and gas development and production. Increased oil and gas development is expected in many areas of the West, due in large part to increased leasing to oil and g as operators on F ederal land. The WRAP has developed the first comprehensive oil and gas inventory in the Western United States, and many states are moving forward with evaluating control options. Wyoming is evaluating and testing many of the control stra tegies, but the specific strategies are not ready for incorporation into this first round of regional haze SIPs. Control options for ozone are being evaluated simultaneously and the State believes that

many co -benefits from controlling emissions for ozone will be realized under the regional haze program. Numerous additional emission reductions from oil and ga s are expected

over the next ten -year period.

6. Wyoming Class I areas have some of the cleanest air in the United States. The haziest days in Wyoming generally have the same level of visibility impairment as the clearest days in the Eastern United S tates. Monitors at visibility sites in Wyoming Class I areas show fine particle load ings that are a fraction of those in the East, and Rayleigh

, or natural light scattering

, dominates the clearest days in the West. Therefore, it is more difficult to show improvement in visibil i ty over time in Wyoming than it is in an Eastern

s tate because the state is starting out so clean.

7. Wyoming is not alone in setting reasonable progress goals which do not achieve the uniform rate of progress. The vast majority of sites in the Western United States will not come close to URP goals primarily because controllable emissions are only a small

fraction of the total contribution t o visibility impairment in the W es tern Class I areas. 5

8. Reasonable progress goals in Wyoming have been based on the control strategies of two major State Implementation Plans - 309 and 309(g). Major work undertaken by the State of Wyoming along with three other Western states and one local entity to cap and reduce

SO 2 emissions represents major progress towards controlling SO 2 . Capping and reducing

SO 2 from all of Wyoming’s 100-ton sources has a bigger impact on nearby Wyoming

Class I areas than Clas s I areas on the Colorado Plateau. The 309 program provides a declining cap for all non-BART 100-ton SO 2 sources through 2018. Visibility

5 Source Contributions to Visibility Imp airment in the Southeastern and Western United States (Patricia Brewer and Tom Moore)130 improvement, as it relates to sulfate extinction, has been demonstrated at all of Wyoming’s Class I areas as a resul t of the application of the 309 program. This visibility

in formation is shown in C hapter 6 of this SIP in Table 6.2-2. Additional work completed for the 309(g) requirements, which is spelled out in great detail in this SIP, provides still further improve ment.

9. Wyoming air quality monitoring for visibility pollutants has not shown a trend toward degraded visibility resulting from anthropogenic sources thus far, in spite of industrial growth. Time series plots of individual chemical species measured for vi sibility on the worst days are shown below. While organic carbon measurements (primarily from forest fires) show a high degree of variability from year to year, sulfates and nitrates (primarily from anthropogenic sources) have not shown a significant degr ee of variation over time.

Figure 7.6-1. Time Series Plot by Pollutant on 20% Worst Days for Yellowstone NP,

Grand Teton NP, and Teton Wilderness Area

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )131 Figure 7.6-2. Time Series Plot by Pollutant on 20% Worst Days for North Absaroka and

Washakie Wilderness Areas

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )

Figu re 7.6 -3. Time Series Plot by Pollutant on 20% Worst Days for Bridger and Fitzpatrick Wilderness Areas

(WRAP TSS

- http://vista.cira.colostate.edu/tss/ )132 

### CHAPTER 8

LONG- TERM STRATEGY

8.1 Overview

The Regional Haze Rule requires states to submit a 10 -15 year long- term strategy (LTS) to address regional haze visibilit y impairment in each Class I area in the state, and for each Class I area outside the state which may be affected by emissions from the state. The LTS must include enforceable measures necessary to achieve reasonable progress goals, and identify allanthropogenic sources of visibility impairment considered by the state in developing the longterm strategy. Where the state contributes to Class I visibility impairment in other states it must consult with those states and develop coordinated emission managem ent strategies, and demonstrate it has included all measures necessary to obtain its share of the emission reductions. If the state has participated in a regional planning process, the state must include measures needed to achieve its obligations agreed upon through that process.

8.1.1 Summary of all Anthropogenic Sources of Visibility Impairment Considered in Developing the L ong- Term Strategy

Section 51.308(d)(3)(iv) of the Regional Haze Rule requires the identification of “all anthropogenic sources of visibility impairment considered by the State when developing its long

term strategy.” Chapter 4 of this Plan describes Wyoming state wide emissions, including projections of emissions reductions from anthropogenic sources from 2002 to 2018. Ch apter 5 of this Plan provides source apportionment results, including projected reductions from anthropogenic sources during the same period. Chapter 5 addresses anthropogenic sources from all potential sources in the world. Chapter 7 includes the results of a screening analysis which identifies the majo r anthropogenic sources in the S tate of Wyoming. Together, these three chapters show the major anthropogenic sources affecting regional haze in Wy oming and in the West. Chapter 7 further describes the ma jor anthropogenic source categories evaluated through

the four- factor analysis.

8.1.2 Summary of Interstate Transport and Contribution

Sections 51.308(d)(3)(i) and (ii) of the Regional Haze Rule requires that the Long- Term Strategy address the contribution of interstate transport of haze pollutants between states. Chapter 4 of this Plan illustrated Wyoming statewide emissions, while Chapter 5 identified interstate transport of pollutants and larger source categories based on source apportionment results.

8.1.2.1 Other States’ Class I Areas Affected by Wyoming Emissions

Wyoming used baseline period visibility data from the IMPROVE monitors along with the WRAP baseline modeling results to estimate Wyoming’s emissions impact on neighboring

states’ Class I areas (see Figure 8.1.2.1-1 ). Wyoming focused on anthropogenic emissions transported to other states, primarily sulfates and nitrates.133 Yellowstone NP Northern Cheyenne Indian Reservation Medicine Lake National Wildlife Refuge

UL Bend National Wildlife Refuge

Badlands NP

Wind Cave NP No rth Absaroka Wilderness

Washakie Wilderness Grand Teton NP

Fitzpatrick Wilderness

Bridger Wilderness Teton Wilderness (Red) Glacier National Park

Gates of the Mountains Wilderness Bob Marshall Wilderness

Mission Mountains Wilderness Scapegoat Wi lderness

Anaconda Pintler Wilderness

Selway

- Bitterroot Wilderness

Sawtooth Wilderness

Craters of the Moon NM

Mount Zirkel Wilderness Rawah Wilderness

Rocky Mountain NP

Flat Tops Wilderness Eagles Nest Wilderness

Maroon Bells

- Snowmass Wilderness

West Elk Wilderness

Black Canyon of the Gunnison
La Garita Wilderness

Weminuche Wilderness Zion National Park Bryce Canyon National Park Capitol Reef NP Canyonlands NP Arches NP Hells Canyon

Wilderness

Mesa Verde NP Wyoming South Dakota Monta na

Idaho

Utah

Colorado Cabinet Mountains

Wilderness

Red Rock Lakes

Great Sand Dunes NP Theodore Roosevelt National Park Lostwood National Wildlife Refuge

North Dakota 

# Figure 8.1.2.1

- 1 Wyoming, South Dakota, Montana, Idaho, Utah, North Dakota a nd Colorado Class I Areas134 In the table below, the first column shows the contribution of nitrates to visibility impairment at surrounding Cl ass I areas calculated from the IMPROVE monitoring data measured during the baseline period to provide perspective on the role of nitrates to overall impairment. The second column shows Wyoming’s contribution to particle mass calculated from the modeled concentrations of nitrate for the baseline years. The table below illustrates two things: 1) the role of nitrates in visibility impairment at the Class I area, and 2) the probable share of Wyoming emissions contributing to the pollutant species.

Table 8.1.2.1-1 . Nitrate Contribution to Haze in Baseline Years

State and Mandatory Class I Area 2000

- 2004 Average Annual Nitrate Share of Particle Light

Extinction (measured values) 2000

- 2004 Wyoming’s Average

Annual Share of Nitrate

Concentration (based on mode ling) Worst Days Best Days Worst Days Best Days

South Dakota

Wind Cave National Park 14% 5% 18% 34%

Badlands National Park 10% 6% 12% 34%

Colorado

Mount Zirkel/Rawah Wilderness* 7% 4% 10% 8% Rocky Mountain National Park 13% 3% 10% 8%

Utah Arches/Canyonlands National Park* 9% 4% 2% 3%

Idaho

Craters of the Moon National Monument 27% 8% 3% <1%

Montana

Anaconda

- Pintler/Selway

- Bitterroot* 3% 3% 3% <1%

Gates of the Mountains Wilderness 6% 4% 2% <1%

North Dakota

Theodore Ro osevelt National Park 22% 7% 4% 7% Lostwood National Wildlife Refuge 31% 8% 3% 2%

* These Class I areas share one monitor.

When modeled, Wyoming NO

x emissions contribute up to 18 percent of the nitrate concentrations at some neighboring states on worst days. As shown in the above table, however, nitrate contributes only 14 percent of the visibility impairment at the corresponding nearest Class I areas in neighboring states. Hence, only a small portion of out-of- state visibility degradation is

due to nit rate formed from Wyoming emissions. By 2018, NO

x emissions from Wyoming are projected by the WRAP to decrease by 39,861 tons, which will help reduce Wyoming’s impact

to out of state Class I areas.135 Table 8.1.2.1-2 . Sulf ate Contribution to Haze in Baseline Years

State and Mandatory Class I Area 2000

- 2004

Aver age Annual Sulfate Share of Particle Light

Extinction (measured values) 2000

- 2004 Wyoming’s Average

Annual Share of Sulfate

Concentration (based on modeling) Worst Days Best Days Worst Days Be st Days

South Dakota

Wind Cave National Park 26% 15% 11% 22%

Badlands National Park 33% 17% 6% 20%

Colorado

Mount Zirkel/Rawah Wilderness* 17% 13% 7% 12% Rocky Mountain National Park 19% 11% 5% 10%

Utah Arches/Canyonlands National Park* 18% 15% 3% 8%

Idaho

Craters of the Moon National Monument 14% 10% 2% 1%

Montana

Anaconda

- Pintler/Selway

- Bitterroot* 11% 8% 2% <1%

Gates of the Mountains Wilderness 17% 8% 1% <1%

North Dakota

Theodore Roosevelt National Park 28% 17% 2% 1 % Lostwood National Wildlife Refuge 29% 19% 1% <1%

* These Class I areas share one monitor.

When modeled, Wyoming sulfate emissions contribute up to 11 percent of the sulfate concentrations at some neighboring states on worst days. As shown in th e abov e table, sulfate

contributes 26 percent of the visibility impairment at the corresponding nearest Class I areas in neighboring states. By 2018, SO 2 emissions from Wyoming are projected by the WRAP to decrease by 22,794 tons, which will help reduce Wyoming ’s impact on out of state Class I areas.

8.1.2.2 Wyoming Class I Areas Affected by Other States, Nations and Areas of the World

The contribution of neighboring states of South Dakota, Colorado, Utah, Idaho and Montana to Wyoming Class I areas was examin ed to determine where significant emissions might be coming from. In the case of both nitrates and sulfates on best and worst days, the most significant impacts on all Wyoming Class I areas came from sources outside the modeling domain. These would be emissions from other parts of the world. This review has focused on nitrates and sulfates since those emissions tend to focus on anthropogenic sources. Data for this impact analysis comes from the PSAT runs performed by the WRAP and documented in the TSS.136 Yellowstone National Park, Grand Teton National Park, and Teton Wilderness Area

• Sulfates

On the best days in the baseline years , 50 percent of the sulfates come from sources outside of the modeling domain. The next largest contribution of sulfates comes from Idaho showing a 14

percent cont ribution to sulfate extinction in the baseline years. Sulfates, overall, contribute

11% to visibility impairment in these Class I areas on the best days. Similarly , on the wor st days, most of the impact (47 %) comes from sources outside the modeling domain. The next largest contrib ution is from Idaho showing an eight percent contribution to sulfate extinction in the baseline years. Sul fates, overall, contribute 12% to visibility impairment in these Class I

ar eas on the worst days. Other states surrounding Wyoming showed smaller contributions (less

than five percent ). Canadian impacts were between six and nine percent on the worst and best days , respectively. Wyoming has worked with Idaho through the WRAP pr ocess and believes that Idaho is working to reduce sulfate impacts to these Class I areas. Idaho is projected by the

WRAP to reduce sulfate related emissions by 13,272 tons by 2018.

• Nitrates

On the be st days in the baseline years, 25 percent of the ni trates come from sources outside the modeling domain. 22 percent is attributed to Idaho and approximately 14 percent to Utah. Other states surrounding Wyoming, and including Wyoming, showed less than five percent impact. Overall impact of nitrates on visibility impairment on the best days is six percent in these Class I

areas. On the worst days in the baseline years, 31 percent of the nitrates come from sources outside of the modeling domain, and 28 percent is attributed to Idaho sources. Other states surrounding Wyoming, and including Wyoming, showed impacts between zero and eight

percent. Overall impacts from n itrates on worst days in these Class I areas is five percent

. Wyoming has worked with both Idaho and Utah through the WRAP process and believ es that both states are working to r educe nitrate impacts to these Class I areas. Idaho is projected by the

WRAP to reduce nitrate causing emissions by 32,418 tons by 2018 and Utah is projected by the

WRAP to reduce nitrate causing emissions by 71,678 tons by 2018.

Bridger and Fitzpatrick Wilderness Areas

• Sulfates

On the be st days in the baseline years, 56 percent of the sulfates come from sources outside of the modeling domain. The next largest contribution of sulfates comes from Idaho, showing a n 18 percent con tribution to sulfate extinction in the baseline years. Other states, including Wyoming , show less than nine percent contribution. Sulfates, overall, contribute 12% to visibility impairment in these C lass I areas on the best days. Similarly , on the worst days, most of the impact (31%) comes from sources outside the modeling domain. The next largest contribution is from Wyoming, showing a 15 percent impact to sulfate extinction in the baseline years. Other states in the region showed less than eight percent impact. Sulfates, overall,

contribute 16% to visibility impairment in these Class I areas on the worst days. Wyoming has worked with Idaho through the WRAP process and believes that Idaho is working to reduce137 sulfate impacts to these Class I areas. Idaho is projected by the WRAP to reduce sulfate related emissions by 13,272 tons by 2018. Emission reductions from Wyoming sources are addressed through the 309 SIP, previously submitted to EPA.

• Nitrates

On the be st days in the baseline ye ars, 30 percent of the nitrates come from sources outside the modeling domain. 24 percent is attributed to Utah and approximately 15 percent to Idaho. Other states surrounding Wyoming, and including Wyoming, showed less than nine percent impact.

Overall impact of nitrates on visibility impairment on the best days is three percent in these Class

I areas. On the worst days in the baseline years, 22 percent of the nitrates come from sources outside of the modeling domain, and 19 percent is attributed to Wyoming. Utah and Ida ho are

estimated to contribute 16 and 11 percent, respectively. Other states surrounding Wyoming showed impacts between one and seven percent. Overall impacts from nitrates on worst days in these Class I areas is five percent . Wyoming has worked with both Idaho and Utah through the WRAP process and believes that both states are working to r educe nitrate impacts to these Class

I areas. Idaho is projected by the WRAP to reduce nitrate causing emissions by 32,418 tons by

2018 and Utah i s projected by the WRAP to reduce nitrate causing emissions by 71,678 tons by 2018. Wyoming is committed to reducing projected WRAP emissions by at least 39,861 tons by

2018.

North Absaroka and Washakie Wilderness Areas

• Sulfates

On the best days in the baseline years, 50 percent of the sulfates come from sources outside of the modeling domain. The next largest contribution of sulfates comes from Canada, showing an 18 percent con tribution to sulfate extinction in the baseline years. Other states, inclu ding Wyoming , show less than ten percent contribution. Sulfates, overall, contribute nine percent to visibility impairment in these Class I areas on the best days. Similarly , on the worst days, most of the impact (50%) comes from sources outside the modeling domain. The next largest contribution is from Canada, showing a 13 percent contribution to sulfate extinction in the baseline years. States in the regio n showed less than seven percent impact. Sulfates, overall,

contribute 15% to visibility impairm ent in these Class I areas on the worst days. EPA is working with Canadian officials to develop cooperative strategies for reducing sulfate emissions from

Canada and the U .S.

• Nitrates

On the best days in the baseline years, 29 percent of the nitrates c ome from sources outside the modeling domain. 14 percent is attributed to Idaho, 13 percent to Canada , and approximately 11 percent from Utah. Other states surrounding Wyoming, and including Wyoming, showed less

than seven percent impact. Overall impact of nitrates on visibility impairment on the best days is

three percent in these Class I areas. On the worst days in the baseline years, 31 percent of the nitrates come from sources outside of the modeling domain, and 17 percent is attributed to Idaho.

Montana and Canada are estimated to contribute 15 and 12 percent, respectively. Other states138 surrounding Wyoming showed impacts between zero and five percent. Overall impacts from

n itrates on worst days in these Class I areas is five percent. Wyoming has worked with Idaho through the WRAP process and believes that Idaho is working to r educe nitrate impacts to these

Class I areas. Idaho is projected to reduce nitrate causing emissions by 32,418 tons by 2018. Montana’s emissions are being address ed by EPA th rough a Federal Implementation Plan, and

nitrate emissions are projected to decrease by 63,099 tons by 2018. EPA is also working with Canadian officials to develop cooperative strategies for reducing nitrate emissions from Canada

and the U.S.

The Div ision consulted with neighboring states as part of this review, and discussed the need for coordinated strategies to address interstate transport. Based on this consultation, no significant contributions were identified that supported developing new inter state strategies. Both Wyoming and neighboring states agreed that the implementation of BART and other existing measures in state regional haze plans were sufficient to address the contributions discussed below. This

interstate consultation is an on

- goin g process and continuing commitment between states. See Chapter 11 for further information.

8.1.3 Summary of Interstate Consultation

In addition to evaluating interstate transport, the affected states are required to consult with each other under Section 51.308(d)(3)(i), in order to develop coordinated emission management strategies. See Section 11 .1 for information on the state- to -state consultation process.

8.1.4 Estimated International and Global Contribution to Wyoming Class I Areas

Although not specifically addressed under the Regional Haze Rule in terms of interstate transport, it is important to identify the contribution to visibility impairment in Wyoming from international sources, such as Canada and Mexico, offshore marine shipping in the P acific Ocean, and “global” sources of haze. The PSAT and WEP results in Chapter 5 describe the amount of contribution to visibility impairment in Wyoming from Canada, Mexico, offshore marine shipping in the Pacific and general gl obal or “outside domain” sources . Because the State of Wyoming does not have any authority over any of the above-mentioned international sources, the Division is not pursuing any new strategy for haze impacts due to international

sources.

The following text was extracted from EPA responses to state questions posed by the WRAP Implemen tation Work Group in March 2007:

The U.S. and Canada have been working on addressing transboundary emissions issues through

the bilateral 1991 Canada- United States Air Quality Agreement. Information , including progress reports and articles, on this agreement can be found at http://www.epa.gov/airmarkets/resource/usaqa-resource.html . Under the agreement, Canada and

the United States have looked at addressing transboundary air pollution, namely, acid rain and ground-level ozone. Over the last two years, Canada and the United States have continued to successfully reduce their emissions of sulfur dioxide (SO 2 ) and nitrogen oxide s (NO

x ), the major contributors to acid rain and also to regional haze. Both countries have also made considerable139 progress in meeting the requirements of the Ozone Annex to reduce emissions of NO

x and volatile organic compounds (VOCs), the precursors to ground-level ozone. Canada and the United States have focused their actions on reducing these emissions from major sources such as electric generating units, industrial sources, and on-road and nonroad transportation.

This Agreement has provided important opportunities for collaboration between Canada and the United States and has produced impressive results, not just in environmental improvements, but also in diplomacy and working relationships. Both countries rely on the Agreement as the

mechanism to a ddress air pollution issues and are committed to its continuing viability and relevance as new bilateral issues emerge. The Agreement’s flexibility provides opportunities to go beyond the challenges identified by the Acid Rain and Ozone annexes, and the Parties look forward to considering whether and how to address bilateral issues associated with particulate matter, mercury, and other air pollutants.

EPA Region 10 has been meeting with their counterparts in the British Columbia Ministry of

Environment fo r the past five years to identify air quality issues in the Georgia

- Basin -Puget Sound Airshed, and to develop an International Airshed Strategy (IAS) to address these issues. The IAS includes protection of visibility as a goal, and the Canadian- United States Air Quality Agreement also addresses visibility. At the most recent IAS meeting in January 2007, the air program director of the BC Ministry of Environment gave a presentation on the process for developing a visibility rule in BC. This rule would be the first of its type in Canada and could be

a model for the rest of Canada. This BC visibility rule would establish a visibility management framework and identify policies needed to achieve visibility protection. A Discussion Paper is being developed on this topic and will be the focus of a workshop this spring with representatives from Canadian air quality agencies, Canadian Tourism, Parks (National and Provincial), Forestry, U.S. EPA, Washington Dept. of Ecology, and U.S. National Park Service.

The re lationship between the air quality improvement programs in Mexico and the United States received formal recognition through the Agreement between the United States and Mexico for Cooperation on the Environment on the U.S.- Mexico Border (the La Paz Agreemen t of 1983). This recognition provided the authority for EPA and Mexico’s Environmental Ministry to conduct cooperative activities to reduce air pollution. In September 1989 the two countries signed Annex V to the La Paz Agreement through which they agreed to cooperatively monitor air quality in sister cities along the U.S. -Mexico border; Annex V was formally expanded in 1996. In February 1992, the environmental authorities of both F ederal governments released the Integrated Border Environmental Plan for the U.S.- Mexico Area (IBEP). The IBEP, a two- year plan, was the first bi-national F ederal initiative created under the assumption that increased liberalization of trade would place additional stress on the environment and human health along the border. The Border XXI Program was initiated in 1996 to build on the experiences of and improve the specific efforts undertaken under the IBEP and earlier environmental agreements.

Pursuant to the La Paz Agreement of 1983, the Administrator of the U.S. Environment al Protection Agency (U.S. EPA) and the Secretary of the Secretariat for the Environment and Natural Resources (SEMARNAT) agreed on October 2001 to work jointly with the ten border states and the U.S. border tribes to develop a new bi-national ten year plan to improve the environment and reduce the highest public health risks on the U.S.-Mexico border. On April 4,140 2003, the representatives of the U.S. EPA, the Secretary of the Secretariat for the Environment and Natural Resources (SEMARNAT), the ten Border States, and the 26 U.S. Tribes, met in Tijuana, Baja California, Mexico to mark the beginning of a ten year joint effort, the Border 2012: U.S.-Mexico Environmental Program replacing the Border XXI Program.

The United States and Mexico, in partnership with border tribal, state, and local governments, have worked to increase the knowledge about air pollution sources and their impacts on both sides of the border, establish monitoring networks in several key areas, conduct emissions inventories, and build local capacity through training.

Pollutants from a number of sources including motor vehicles, power plants and industrial facilities, agricultural operations, mining, dust from unpaved roads, and open burning have affected urban and regional air quality a long the U.S.-Mexico border. The most common and damaging pollutants from these sources include sulfur dioxide, suspended particulate matter (PM 10 and PM 2.5 ), nitrogen dioxide, ground-level ozone, and carbon monoxide.

To provide technical assistance about air quality planning and management to government, academia, industry, and the general public in the border region, the U.S. and Mexico established the Centro de Informacion sobre Contaminacion de Aire (CICA, or Border Information Center on Air Pollution). The CICA Program, which is implemented by the Clean Air Technology Center of EPA’s Office of Air Quality Planning and Standards, has established a website at http://www.epa.gov/ttn/catc/cica

.

The Big B end Regional Aerosol and V isibility Observational (BRAVO) Study was conducted to quantify the contribution to visibility degradation at Big Bend National Park (BBNP) from various air pollution source regions and source types in the U.S. and Mexico. The st udy included evaluation of the impacts from the Carbon 1-2 power plants in Coahuila, 18 miles from the U.S. border. Findings from the BRAVO study can be found at http://www2.nature.nps.gov/air/studies/bravo/index.htm

.

Beginning in 2003 an effort was undertaken to understand better the smoke/haze from spring burning in Central America/Mexico, which prompted State Department of Health alerts for up to 70% of the population of Texas on some days. Components of this effort include an ambient study of particle chemical constituents to determine the sources of haze; remote sensing analysis to evaluate locations of the burning and to assess the potential seriousness of such burning to

transp ort of particles in Texas; and on-the-ground assessment of ways to fight the fires and mitigate damage.

Under the Border 2012 Program bi-national efforts have continued with the transfer of the northern Baja California network to the State of Baja California, update of existing emissions inventories, and the completion of the first Mexico National Emissions Inventory.

Additionally, the United States and Mexico in partnership with border tribal, state, and local governments, are working together on projects such as retrofitting diesel trucks and school buses with either diesel oxidation catalysts or diesel particulate filters to operate on ultra low sulfur141 diesel fuel, constructing “lower polluting” or “environmentally friendly” brick kilns, and road paving to reduce the levels of particulate matter in the border region.

8.2 Required Factors for the Long

- Term Strategy

As required in Section 51.308(d)(3)(v) of the Regional Haze Rule, the S tate must consider, at a minimum, the following factors: 1) emissio n reductions due to ongoing air pollution control programs; 2) measures to mitigate the impacts of construction activities; 3) emission limitations and schedules for compliance; 4) source retirement and replacement schedules; 5) smoke management techniques for agricultural and forestry burning; 6) the enforceability of emission limitations and control measures; and 7) the anticipated net effect on visibility over the period of the long- term strategy. These factors are discussed in the following pages along with all measures to mitigate the impacts of anthropogenic sources. The seventh factor is discussed at the end of the Long- Term Strategy Chapter.

8.2.1 Emission Reductions Due to Ongoing Air Pollution Control Programs

The following summary describes o ngoing programs and regulations in Wyoming that directly protect visibility, or can be expected to improve visibility in Wyoming Class I areas, by reducing emissions in general. This summary does not attempt to estimate the actual improvements in visibility that will occur, as many of the benefits are secondary to the primary air pollution objective of these programs/rules, and consequently would be extremely difficult to quantify due to the technical complexity and limitations in current assessment techni ques.

8.2.1 .1 New Source Review Program

The New Source Review (NSR) Program is a permit program for the construction of new sources and modification of existing sources as established by WAQSR Chapter 6, Section 2, Permit requirements for construction, modification and operation and Chapter 6, Section 4, Prevention of significant deterioration. Section 2 of Chapter 6 first became a State rule in 1974, with the most recent revision being in March of 2000. Section 2 was submitted to EPA on September 12, 2003, approved by EPA on July 28, 2004, and became effective on August 27, 2004. The primary purpose of the NSR Program is to assure compliance with ambient standards set to protect public health, assure that Best Available Control Technology (BACT) is ut ilized to reduce and eliminate air pollution emissions, and to prevent deterioration of clean air areas. Any amount of air contaminant emissions from a facility subjects it to Wyoming’s NSR Program.

8.2.1.1.1 Prevention of Significant Deterioration (PSD ) Program

Generally, Wyoming considers its Prevention of Significant Deterioration (PSD) program as being protective of visibility impairment from proposed major stationary sources or major modifications to existing facilities. Wyoming has a fully -approved PSD program, and has successfully implemented this program for many years. Wyoming’s PSD rules (Chapter 6, Section 4, of the Wyoming Air Quality Standards and Regulations (WAQSR)) were revised

effective Oc tober 6, 2006, to conform with F ederal NSR Reform rules. These changes were142 submitted to EPA on December 13, 2006, approved by EPA on July 16, 2008, and became effective on August 15, 2008.

8.2.1.1.2 Minor Source BACT Program

The BACT process is most appropriately defined as the elimination of po llutants from being emitted into the air whenever technically and ec onomically feasible to do so. For example, b y application of minor source BACT, the Division has required controls of NO

x and formaldehyde in coal bed methane (CBM) development and contro ls of NO

x , VOC and Hazardous AirPollutant (HAP) emissions in oil and gas production development. The Division takes the Staterequired BACT review in minor source permitting actions very seriously, as the bulk of the Division’s workload is made up of minor sources.

The Division will continue to review BACT considerations on each source type and size on a

case

- by

- case basis with consideration to the technical practicability and economic reasonableness of eliminating or reducing the emissions from the proposed facility. The application of BACT in the minor source permitting program has resulted in minimized emissions in the s tate as a whole and will continue to do so as the Division continues to receive NSR permit applications for new

and modified sources.

8.2.1.2 Title V Operating Permit Program

As required by Title V of the Clean Air Act Amendments of 1990 and the implementing regulations in 40 CFR part 70, Wyoming established an Operating Permit Program under Chapter 6, Section 3 of the WAQSR. Wyomin g’s proposed program was submitted to the Environmental Protection Agency (EPA) for approval on November 22, 1993. Notice of Interim Approval was published in the Federal Register on January 19, 1995. Final EPA approval of the Wyoming Operating Permit Pr ogram was published on February 22, 1999, and the approval was effective April 23, 1999.

A Title V Operating Permit consolidates all air quality regulatory requirements in a single document, so a permittee can clearly determine compliance with the air qua lity environmental laws governing its operation. The Title V Operating Permit also establishes appropriate compliance assurance monitoring on a pollutant- by -pollutant basis for large emission sources with add-on pollution control equipment, and/or establishes periodic monitoring for other regulated pollutants. The process of issuing the Operating Permit is designed to allow participation by the public, the EPA and nearby states to avoid misinterpretation of air quality regulatory requirements. This permitting is done to enhance enforceability by clearly defining the playing field for all concerned parties, such that all regulated industry is governed by the

same rules. These permits are issued for a term of five years and must be renewed and updated to incorporate current regulatory requirements. Nationally, this program is intended to set minimum standards for all states to implement, in an attempt to foster consistency in air quality permitting from state to state. The Operating Permit Program is inte nded to be self supporting, and states are required under the Clean Air Act to charge regulated industry fees based upon their actual air pollutant emissions on an an nual basis; thus, Title V permit tees pay for the operation of the regulating program.143 The Operating Permit Program currently affects only major sources of air pollution operating in

the State . A major source is defined as a source which emits, or has the potential to emit, 100 tons per year of an air pollutant, or any source which emits, or h as the potential to emit, 10 tons per year of an individual hazardous air pollutant (or 25 tons per year of any combination of hazardous air pollutants) which has been listed pursuant to section 112(b) of the Clean Air Act. The number of Title V sources within the State is highly variable but has typically ranged from 150 to 160 sources at any given time.

In December of 2000, WAQSR Chapter 6, Section 3 Operating permits , was revised to incorporate compliance assurance monitoring (CAM). CAM is intended to provide a reasonable assurance of compliance with applicable requirements under the Clean Air Act for large emission units that rely on pollution control device equipment to achieve compliance. Monitoring is conducted to determine that control devices, once installed or otherwise employed, are properly operated and maintained so that they continue to achieve a level of control that complies with applicable requirements. The Division is addressing the complex implementation of CAM in renewals, significant modifications and new permits, as applicable. The implementation of CAM will result in documenting continued operation of control devices, within ranges of specified indicators of performance, that are designed to provide reasonable assurance of compliance with applicable requirements.

8.2.1.3 New Source Performance Standards (NSPS)

The Air Quality Division annually incorporates by reference the Federal New Source Performance Standards (NSPS). These standards are incorporated via the Wyoming Air Quali ty Standards and Regulations, Chapter 5, Section 2. Section 2 first became an effective State rule in November 1976, with the latest revision becoming effective in May 2008. Section 2 was last submitted to the EPA on August 27, 2008, approved by EPA on March 9, 2009, and became effective on March 9, 2009. The list of NSPS incorporated by reference include:

40 CFR part 60, Subpart D - Standards of Performance for Fossil

- Fuel

- Fired Steam Generators for Which

Construction is Commenced After August 17, 1971

40 CFR part 60, Subpart Da - Standards of Performance for Electric Utility Steam Generating Units for Which

Construction is Commenced After September 18, 1978

40 CFR part 60, Subpart Db - Standards of performance for Industrial-

Commercial

- Institutional Steam Generating

Units144 40 CFR part 60, Subpart Dc - Standards of Performance for Small

Industrial- Commercial

- Institutional Steam Generating Units

40 CFR part 60, Subpart E - Stan dards of Performance for Incinerators

40 CFR part 60, Subpart Ea - Standards of Performance for Municipal

Waste Combustors for Which Construction is Commenced After December 20, 1989 and on or Before September 20, 1994

40 CFR part 60, Subpart Eb - Standards of Performance for Large Municipal Waste Combustors for Which

Construction is Commenced After September 20, 1994 or for Which

Modification or Reconstruction is Commenced After June 19, 1996

40 CFR part 60, Subpart Ec - Standards of Performance for Hospital/Medical/Infectious Waste

Incinerators for Which Construction is Commenced After June 20, 1996

40 CFR part 60, Subpart F - Standards of Performance for Portland

Cement Plants

40 CFR part 60, Subpart G - Standards of Performance for Nitric Acid

Plants

40 CFR part 60, Subpart H - Standards of Performance for Sulfuric Acid

Plants

40 CFR part 60, Subpart I - Standards of Performance for Hot Mix Aspha lt Facilities

40 CFR part 60, Subpart J - Standards of Performance for Petroleum

Refineries

40 CFR part 60, Subpart K - Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or

Modification Commenced After June 11, 1973, and Prior to May 19, 1978145 40 CFR part 60, Subpart Ka - Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or

Modification C ommenced After May 18, 1978, and Prior to July 23, 1984

40 CFR part 60, Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23,

1984

40 CFR part 60, Subpart L - Standards of Performance for Secondary

Lead Smelters

40 CFR part 60, Subpart M - Standards of Performance for Secondary

Brass and Bronze Produ ction Plants

40 CFR part 60, Subpart N - Standards of Performance for Primary Emissions from Basic Oxygen Process

Furnaces for Which Construction is Commenced After June 11, 1973

40 CFR part 60, Subpart Na - Standards of Performance for Secondary Emissions from Basic Oxygen Process Steelmaking Facilities for Which Construction is Commenced After January 20, 1983

40 CFR part 60, Subpart O - Standards of Performance for Sewage

Treatment Plants

40 CFR part 60, Subpart P - Standards of Performance for Primary Copper Smelters

40 CFR part 60, Subpart Q - Standards of Performance for Primary Zinc

Smelters

40 CFR part 60, Subpart R - Standards of Performance for Primary Lead

Smelters

40 CFR part 60, Subpart S - Standards of Performance for Primary

Aluminum Reduction Plants146 40 CFR part 60, Subpart T - Standards of Performance for the Phosphate Fertilizer Industry: Wet -Process Phosphoric

Acid Plants

40 CFR part 60, Subpart U - Standards of Performance for the Phosphate Fertilizer Industry: Superphosphoric Acid

Plants

40 CFR part 60, Subpart V - Standards of Performance for the Phosphate Fertilizer Industry: Diammonium Phosphate

Pl ants

40 CFR part 60, Subpart W - Standards of Performance for the Phosphate Fertilizer Industry: Triple Superphosphate

Plants

40 CFR part 60, Subpart X - Standards of Performance for the Phosphate Fertilizer Industry: Granular Tri ple Superphosphate Storage Facilities

40 CFR part 60, Subpart Y - Standards of Performance for Coal Preparation Plants

40 CFR part 60, Subpart Z - Standards of Performance for Ferroalloy

Production Facilities

40 CFR part 60, Subpa rt AA

- Standards of Performance for Steel Plants:

Electric Arc Furnaces Constructed After October 21, 1974 and on or Before August 17, 1983

40 CFR part 60, Subpart AAa - Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon

- Oxygen

Decarburization Vessels Constructed After August 17, 1983

40 CFR part 60, Subpart BB - Standards of Performance for Kraft Pulp

Mills

40 CFR part 60, Subpart CC - Standards of Performance for Glass

Manufa cturing Plants

40 CFR part 60, Subpart DD - Standards of Performance for Grain

Elevators147 40 CFR part 60, Subpart EE - Standards of Performance for Surface Coating of Metal Furniture

40 CFR part 60, Subpart GG - Standards of Performance for Stationary Gas

Turbines

40 CFR part 60, Subpart HH - Standards of Performance for Lime Manufacturing Plants

40 CFR part 60, Subpart KK - Standards of Performance for Lead

- Acid Battery Manufacturing Plants

40 CFR part 60, Subpart LL

- Standards of Performance for Metallic Mineral Processing Plants

40 CFR part 60, Subpart MM - Standards of Performance for Automobile and Light -Duty Truck Surface Coating Operations

40 CFR part 60, Subpart NN - Standards of Performance for Phosphate

Rock Plants

40 CFR part 60, Subpart PP - Standards of Performance for Ammonium

Sulfate Manufacture

40 CFR part 60, Subpart QQ - Standards of Performance for the Graphic Arts Industry: Publication Rotogravure Printing

40 CFR part 60, Subpart RR - Standards of Performance for Pressure Sensitive Tape and Label Surface Coating Operations

40 CFR part 60, Subpart SS - Standards of Performance for Industrial Surface Coating: Large Appliances

40 CFR part 60, Subpart TT - Standards of Performance for Metal Coil Surface Coating

40 CFR part 60, Subpart UU - Standards of Performance for Asphalt Processing and Asphalt Roofing

Manufacture

40 CFR part 60, Subpart VV - Stan dards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry148 40 CFR part 60, Subpart WW - Standards of Performance for the Beverage Can Surface Coating Industry

40 CFR part 60, Subpart XX - Standards of Performance for Bulk Gasoline

Terminals

40 CFR part 60, Subpart AAA - Standards of Performance for New

Residential Wood Heaters

40 CFR part 60, Subpart BBB - Standards of Performance for the Rubber Tire Manufacturing Ind ustry

40 CFR part 60, Subpart DDD - Standards of Performance for Volatile Organic Compound (VOC) Emissions from the Polymer Manufacturing Industry

40 CFR part 60, Subpart FFF - Standards of Performance for Flexible Vinyl

and Urethane Coating and Printing

40 CFR part 60, Subpart GGG - Standards of Performance for Equipment

Leaks of VOC in Petroleum Refineries

40 CFR part 60, Subpart HHH - Standards of Performance for Synthetic

Fiber Production Facilities

40 CFR part 60, Subpart III - Standards of Performance for Volatile Organic Compound (VOC) Emissions From the Synthetic Organic Chemical Manufacturing Industry (SOCMI) Air

Oxidation Unit Processes

40 CFR part 60, Subpart JJJ - Standards of Pe rformance for Petroleum Dry

Cleaners

40 CFR part 60, Subpart KKK - Standards of Performance for Equipment

Leaks of VOC From Onshore Natural Gas Processing Plants

40 CFR part 60, Subpart LLL - Standards of Performance for Onshore Natural Gas Processing: SO 2 Emissions

40 CFR part 60, Subpart NNN - Standards of Performance for Volatile Organic Compound (VOC) Emissions From Synthetic Organic Chemical Manufacturing Industry (SOCMI) Distillation Operations149 40 CFR part 60, Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants

40 CFR part 60, Subpart PPP - Standards of Performance for Wool Fiberglass Insulation Manufacturing Plants

40 CFR part 60, Subpart QQQ - Standards of Performance for VOC Emissions From Petroleum Refinery Wastewater Systems

40 CFR part 60, Subpart RRR - Standards of Performance for Volatile Organic Compound Emissions from Synthetic Organic Chemical Manufacturing Industry (SOCMI) Reactor Processes

40 CFR part 60, Subpart SSS - Standards of Performance for Magnetic Tape Coating Facilities

40 CFR part 60, Subpart TTT - Standards of Performance for Industrial Surface Coating: Surface Coating of Plastic

P arts for Business Machines

40 CFR part 60, Subpart UUU - Standards of Performance for Calciners and Dryers in Mineral Industries

40 CFR part 60, Subpart VVV - Standards of Performance for Polymeric Coating of Supporting Substrates Facilitie s

40 CFR part 60, Subpart WWW - Standards of Performance for Municipal

Solid Waste Landfills

40 CFR part 60, Subpart AAAA - Standards of Performance for Small Municipal Waste Combustion Units for

Which Construction is Commenced After August 30, 1999 or for Which Modification

or Reconstruction is Commenced After June 6, 2001

40 CFR part 60, Subpart CCCC - Standards of Performance for Commercial

and Industrial Solid Waste Incineration

Units for Which Construction is Commenced After November 30, 1999 or

for Which Modification or Reconstruction is Commenced on or After June 1, 2001150 40 CFR part 60, Subpart EEEE - Standards of Performance for Other Solid Waste

Incineration Units for Wh ich Construction is

Commenced After December 9, 2004, or for Which

Modification or Reconstruction is Commenced on or After June 16, 2006

8.2.1.4 MACT
- HAPs Program

The Air Quality Division annually incorporates by reference the Federa l National Emission Standards for Hazardous Air Pollutants (NESHAPs). To the extent that NESHAPs regulate visibility impairing pollutants through surrogates, these programs may prove helpful in reducing visibility impairment. These standards are incorporated via the Wyoming Air Quality Standards and Regulations, Chapter 5, Section 3. Section 3 first became an effective State rule in August of 1997, with the latest revision becoming effective in May 2008. The delegation request for

Section 3 was submitte d to the EPA in June of 2008. The list of NESHAP (MACT) standards incorporated by reference include:

40 CFR part 63, Subpart D - Regulations Governing Compliance Extensions for Early Reductions of

Hazardous Air Pollutants

40 CFR part 63, Subpart F - National Emission Standards for Organic Hazardous Air Pollutants From the Synthetic Organic Chemical Manufacturing Industry

40 CFR part 63, Subpart G - National Emission Standards for Organic Hazardous Air Pollutants From the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater

40 CFR part 63, Subpart H - National Emission Standards for Organic Hazard ous Air Pollutants for Equipment Leaks

40 CFR part 63, Subpart I - National Emission Standards for Organic Hazardous Air Pollutants for Certain Processes Subject to the Negotiated Regulation for Equipment Leaks151 40 CFR part 63, Subpart J - National Emission Standards for

Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers

Production

40 CFR part 63, Subpart L - National Emission Standards for

Coke Oven Batteries

40 CFR part 63, Subpart M - National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities

40 CFR part 63, Subpart N - National Emission Standards for

Chromium Emissions From Hard

and Decorative Chromium

Ele ctroplating and Chromium Anodizing Tanks

40 CFR part 63, Subpart O - Ethylene Oxide Emissions

Standards for Sterilization

Facilities

40 CFR part 63, Subpart Q - National Emission Standards for

Hazardous Air Pollutants for Industrial Process Cooling

Towers

40 CFR part 63, Subpart R - National Emission Standards for

Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations)

40 CFR part 63, Subpart S - National Emission Standards for

Hazardous Air Pollutants from the Pulp and Paper Industry

40 CFR part 63, Subpart T - National Emission Standards for Halogenated Solvent Cleaning

40 CFR part 63, Subpart U - National Emission Standards for

Hazardous Air Pollutant Emissions: Group I Polymers and Resins152 40 CFR part 63, Subpart W - National Emission Standards for

Hazardous Air Pollutants for Epoxy Resins Production and Non-Nylon Polyamides

Production

40 CFR part 63, Subpart X - National Emission Standards for

Hazardous Air Pollutants from Secondary Lead Smelting

40 CFR part 63, Subpart Y - National Emission Standards for Marine Tank Vessel Loading Operations

40 CFR part 63, Subpart AA - National Emission Standards for

Hazardous Air Pollutants From Phosphoric Acid Manufacturing

Plants

40 CFR part 63, Subpart BB - National Emission Standards for

Hazardous Air Pollutants From Phosphate Fertilizers Production

Plants

40 CFR part 63, Subpart CC - National Emission Standards for

Hazardous Air Pollutants From

Petroleum Refineries

40 CFR part 63, Subpart DD - National Emission Standards for

Hazardous Air Pollutants from

Off

- Site Waste and Recovery Operations

40 CFR part 63, Subpart EE - National Emission Standards for Magnetic Tape Manufacturing Operations

40 CFR part 63, Subpart GG - National Emissi on Standards for Aerospace Manufacturing and

Rework Facilities

40 CFR part 63, Subpart HH - National Emission Standards for

Hazardous Air Pollutants From

O il and Natural Gas Production

Facilities153 40 CFR part 63, Subp art II - National Emission Standards for Shipbuilding and Ship Repair (Surface Coating)

40 CFR part 63, Subpart JJ - National Emission Standards for Wood Furniture Manufacturing Operations

40 CFR part 63, Subpart KK - National Emission Standards for the Printing and Publishing Industry

40 CFR part 63, Subpart LL - National Emission Standards for

Hazardous Air Pollutants for Primary Aluminum Reduction Plants

40 CFR part 63, Subpart MM - National Emission Standards for

Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite,

and Stand- Alone Semichemical Pulp Mills

40 CFR part 63, Subpart OO - National Emission Standards for

Tanks - Level 1

40 CFR part 63, Subpart PP - National Emission Standards for

Containers

40 CFR part 63, Subpart QQ - National Emission Standards for Surface Impoundments

40 CFR part 63, Subpart RR - National Emission Standard s for Individual Drain Systems

40 CFR part 63, Subpart SS - National Emission Standards for Closed Vent Systems, Control Devices, Recovery Devices and Routing to a Fuel Gas System

or a Process

40 CFR part 63, Subpar t TT - National Emission Standards for Equipment Leaks - Control Level 1

40 CFR part 63, Subpart UU - National Emission Standards for Equipment Leaks

- Control Level

2 S tandards154 40 CFR part 63, Subpart VV - National Emission St andards for

Oil

- Water Separators and Organic

Water Separators

40 CFR part 63, Subpart WW - National Emission Standards for Storage Vessels (Tanks) - Control

Level 2

40 CFR part 63, Subpart XX - National Emission Standard s for Ethylene Manufacturing Process Units: Heat Exchange Systems and Waste Operations

40 CFR part 63, Subpart YY - National Emission Standards for

Hazardous Air Pollutants for Source Categories: Generic

Maximu m Achievable Control Technology Standards

40 CFR part 63, Subpart CCC - National Emission Standards for

Hazardous Air Pollutants for Steel Pickling

- HCl Process Facilities and Hydrochloric Acid Regeneration Plants

40 CFR part 63, Subpart DDD - National Emission Standards for

Hazardous Air Pollutants for

Mineral Wool Production

40 CFR part 63, Subpart EEE - National Emission Standards for

Hazardous Air Pollutants from

Hazardous Waste Co mbustors

40 CFR part 63, Subpart GGG - National Emission Standards for

Pharmaceuticals Production

40 CFR part 63, Subpart HHH - National Emission Standards for

Hazardous Air Pollutants From

Natural Gas Transmission and

Sto rage Facilities

40 CFR part 63, Subpart III - National Emission Standards for

Hazardous Air Pollutants for

F lexible Polyurethane Foam

Production155 40 CFR part 63, Subpart JJJ - National Emission Standards for

Hazardous Air Pollutant Emissions: Group IV Polymers and Resins

40 CFR part 63, Subpart LLL - National Emission Standards for

Hazardous Air Pollutants From the Portland Cement Manufacturing Industry

40 CFR part 63, Subpart MMM - Nation al Emission Standards for

Hazardous Air Pollutants for Pesticide Active Ingredient

Production

40 CFR part 63, Subpart NNN - National Emission Standards for

Hazardous Air Pollutants for Wool Fiberglass Manufacturing

40 CFR part 63, Subpart OOO - National Emission Standards for

Hazardous Air Pollutant Emissions:

Manufacture of Amino/Phenolic

Resins

40 CFR part 63, Subpart PPP - National Emission Standards for

Hazardous Air Pollutants for Polyether Polyols Production

40 CFR part 63, Subpart QQQ - National Emission Standards for

Hazardous Air Pollutants for Primary Copper Smelting

40 CFR part 63, Subpart RRR - National Emission Standards for

Hazardous Air Po llutants for Secondary Aluminum Production

40 CFR part 63, Subpart TTT - National Emission Standards for

Hazardous Air Pollutants for Primary Lead Smelting

40 CFR part 63, Subpart UUU - National Emission Standards for

Haza rdous Air Pollutants for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur

R ecovery Units156 40 CFR part 63, Subpart VVV - National Emission Standards for

Hazardous Air Pollutants: Publicly

Owned Treatment Works

40 CFR part 63, Subpart XXX - National Emission Standards for

Hazardous Air Pollutants for Ferroalloys Production: Ferromanganese and Silicomanganese

40 CFR part 63, Subpart AAAA - Natio nal Emission Standards for

Hazardous Air Pollutants: Municipal Solid Waste Landfills

40 CFR part 63, Subpart CCCC - National Emission Standards for

Hazardous Air Pollutants: Manufacturing of Nutritional Yeast

40 CFR part 63 , Subpart DDDD - National Emission Standards for

Haz ardous Air Pollutants: Plywood and Composite Wood Products

40 CFR part 63, Subpart EEEE - National Emission Standards for Hazardous Air Pollutants: Organic Liquids Distri bution (Non- Gasoline)

40 CFR part 63, Subpart FFFF - National Emission Standards for

Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing

40 CFR part 63, Subpart GGGG - National Emission Standards for

Haz ardous Air Pollutants: Solvent Extraction for Vegetable Oil

Production

40 CFR part 63, Subpart HHHH - National Emission Standards for

Hazardous Air Pollutants for Wet- Formed Fiberglass Mat Production

40 CFR part 63, Subp art IIII - National Emission Standards for

Hazardous Air Pollutants: Surface Coating of Automobiles and Light-

D uty Trucks157 40 CFR part 63, Subpart JJJJ - National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating

40 CFR part 63, Subpart KKKK - National Emission Standards for

Hazardous Air Pollutants: Surface Coating of Metal Cans

40 CFR part 63, Subpart MMMM - National Emission Standards for

Hazardous Air Pollut ants for Surface Coating of Miscellaneous Metal

Parts and Products

40 CFR part 63, Subpart NNNN - National Emission Standards for

Hazardous Air Pollutants: Surface Coating of Large Appliances

40 CFR part 63, Subpart OOOO - National Emission Standards for

Hazardous Air Pollutants: Printing, Coating, and Dyeing of

Fabrics and Other Textiles

40 CFR part 63, Subpart PPPP - National Emission Standards for

Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products

40 CFR part 63, Subpart QQQQ - National Emission Standards for

Hazardous Air Pollutants: Surface Coating of Wood Building Products

40 CFR part 63, Subpart RRRR - National Emission Standards for

Hazardous Air Pollutants: Surface Coating of Metal Furniture

40 CFR part 63, Subpart SSSS - National Emission Standards for

Hazardous Air Pollutants: Surface Coating of Metal Coil

40 CFR part 63, Subpart TTTT - Nati onal Emission Standards for

Hazardous Air Pollutants for Leather Finishing Operations

40 CFR part 63, Subpart UUUU - National Emission Standards for

Hazardous Air Pollutants for

C ellulose Products Manufacturing158 40 CFR part 63, Subpart VVVV - National Emission Standards for

Hazardous Air Pollutants for Boat Manufacturing

40 CFR part 63, Subpart WWWW - National Emissions Standards for

Hazardous Air Pollutants: Reinforced Plastic Composites

Production

40 CFR part 63, Subpart XXXX - National Emission Standards for

Hazardous Air Pollutants: Rubber Tire Manufacturing

40 CFR part 63, Subpart YYYY - National Emission Standards for

Hazardous Air Pollutants for Stationary Combustion Turbines

40 CFR part 63, Subpart ZZZZ - National Emission Standards for

Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

40 CFR part 63, Subpart AAAAA - National Emissions Sta ndards for

Hazardous Air Pollutants for Lime Manufacturing Plants

40 CFR part 63, Subpart BBBBB - National Emission Standards for

Hazardous Air Pollutants for Semiconductor Manufacturing

40 CFR part 63, Subpart CCCCC - Nat ional Emission Standards for

Hazardous Air Pollutants for Coke Ovens: Pushing, Quenching, and Battery Stacks

40 CFR part 63 , Subpart DDDDD - National Emission Standards for

Hazardous Air Pollutants for Industrial, Com mercial, and

Institutional Boilers and Process

Heaters

40 CFR part 63, Subpart EEEEE - National Emission Standards for

Hazardous Air Pollutants for Iron

and Steel Foundries159 40 CFR part 63, Subpart FFFFF - National Emission Standards for

Hazardous Air Pollutants for Integrated Iron and Steel Manufacturing Facilities

40 CFR part 63, Subpart GGGGG - National Emission Standards for

Hazardous Air Pollutants: Site

Remediation

40 CFR part 6 3, Subpart HHHHH - National Emission Standards for

Hazardous Air Pollutants: Miscellaneous Coating Manufacturing

40 CFR part 63, Subpart IIIII - National Emission Standards for Hazardous Air Pollutants: Mercury

Emiss ions From Mercury Cell

Chlor- Alkali Plants

40 CFR part 63, Subpart JJJJJ - National Emission Standards for

Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing

40 CFR part 63, Subpart KKKKK - Natio nal Emission Standards for Hazardous Air Pollutants for Clay Ceramics Manufacturing

40 CFR part 63, Subpart LLLLL - National Emission Standards for Hazardous Air Pollutants: Asphalt Processing and Asphalt Roofing Manufacturing

40 CFR part 63, Subpart MMMMM - National Emission Standards for

Hazardous Air Pollutants: Flexible Polyurethane Foam Fabrication Operations

40 CFR part 63, Subpart NNNNN - National Emission Standards for

Hazardou s Air Pollutants: Hydrochloric Acid Production

40 CFR part 63, Subpart PPPPP - National Emission Standards for

Hazardous Air Pollutants for

E ngine Test Cells/Stands160 40 CFR part 63, Subpart QQQQQ - National Emission Standards for

Hazardous Air Pollutants for Friction Materials Manufacturing

Facilities

40 CFR part 63, Subpart RRRRR - National Emission Standards for

Hazardous Air Pollutants: Taconite Iron Ore Processing

40 CFR part 63, Subpart SSSSS - National Emission Standards for

Hazardous Air Pollutants for Refractory Products Manufacturing

40 CFR part 63, Subpart TTTTT - National Emissions Standards for Hazardous Air Pollutants for Primary Magnesium Refining

The Air Quality Division also determines case

- by -case MACT determinations through Chapter 6, Section 6.

8.2.1.5 Phase I Visibility Rules
- Wyoming Reasonably Attributable Visibility Impairment

Rules

In response to EPA’s Phase I visibility rules, Wyoming adopted the Wyoming State Implementation Plan for Class I Visibility Protection, effective May 10, 1988. It was approved by the U.S. EPA by notice in the Federal Register on February 15, 1989, under 40 CFR part 52,

and became effective on April 17, 1989. This visibility rule contains short and long- term strategies for making reasonable progress toward the national goal, related to addressing reasonably attributable impairment in the State’s Class I areas through visibility monitoring and control strategies. This rule incorporates PSD requirements for visibility protection from new or modified major stationary sources, and if necessary applying BART to existing stationary sources if certified as causing reasonably attributable visibility impairment.

8.2.1.6 Ongoing Implementation of Federal Mobile Source Regulations

The Federal Motor Vehicle Control Program (FMVCP) has produced and is continuing to produce large reductions in motor vehicle emissions of NO

x , PM, and VOCs. Beginning in 2006, EPA mandated new standards for on-road (highway) diesel fuel, known as ultra-low sulfur diesel (ULSD). This regulation dropped the sulfur content of diesel fuel from 500 ppm to 15 ppm. ULSD fuel enables the use of cleaner technology diesel engines and vehicles with advanced emissions control devices, resulting in significantly lower emissions. Diesel fuel intended for locomotive, marine and non-road (farming and construction) engines and equipment was required to meet the low sulfur diesel fuel maximu m specification of 500 ppm sulfur in 2007 (down from 5,000 ppm). By 2010, the ULSD fuel standard of 15- ppm sulfur will apply to all non-road diesel fuel. Locomotive and marine diesel fuel will be required to meet the ULSD161 standard beginning in 2012, resulting in further reductions of diesel emissions. These rules not only reduce SO 2 emissions, but also NO

x and PM emissions.

In addition to the ULSD standard, listed below are several other significant F ederal programs:

Federal On

- Road Measures

● Tier 2 vehicle emission standards and F ederal low

- sulfur gasoline

● National low emissions vehicle standards (NLEV)

● Heavy -duty diesel standards

Federal Non

- Road Measures

● Lawn and garden equipment

● Tier 2 heavy -duty diesel equipment

● Locomotive engine standards

● Compression ignition standards for vehicles and equipment

● Recreational marine engine standards

In addition, the Renewable Fuel Standard Under Section 211(o) of the Clean Air Act as Amended by the Energy Policy Act of 2005 , is determined annually (must be published in the Federal Register by November 30 of each year) by EPA and is applicable to refiners, importers and blenders of gasoline.

8.2.1.7 Ongoing Implementation of Programs to Meet PM 10 NAAQS

Currently, only one community in Wyoming, Sheridan, is designated as a nonattainment area

under the PM 10 National Ambient Air Quality Standard (NAAQS) . The significance of this nonattainment area in terms of regional haze is that significant reductions in PM 10 emissions

have been ma de in the last ten years, by adopting strategies to address the primary emission sources in the community. The major contributing sources causing nonattainment in this community are road dust, residentia l woodstoves, outdoor burning, and to a lesser degre e, industry.

8.2.1.7.1 Nonattainment SIP (PM 10 ) - City of Sheridan

Because Sheridan, Wyoming was designated a Group I area under the PM 10 Regulations promulgated by the EPA on July 20, 1987, the Air Quality Division was required to develop a State Imple mentation Plan outlining control strategies with a demonstration of attainment and maintenance of the standards. In cooperation with the Sheridan City government, a plan was developed which addressed four PM 10 control measures.

The first control measure involved implementing a sanding plan or air quality maintenance plan (AQMP), which aimed to reduce PM 10 emissions by designating specific limitations/guidelines for sanding routes, sanding mediums, application rates, and street cleaning.

The second control measure was a voluntary curtailment of solid fuels combustion, whereby an ordinance was enacted allowing the designation of voluntary “no burn days” when PM 10162 concentrations exceed or are predicted to exceed established criteria levels. The Division

col lects “real time” particulate data and uses the information in conjunction with weather predictions to trigger requests for burning curtailment.

Fugitive dust concerns comprised the third control measure. Several industrial areas in the City of Sheridan were identified as significant sources of fugitive dust. The Division required that these facilities submit a dust control plan specifying as a minimum, application of asphalt, oil, or suitable chemical dust control agents on unpaved roads within their op erations. One facility was

asked to use more durable washed sand rather than scoria for skid control.

Because some of the streets of Sheridan are maintained by the County and the Highway Department, as a fourth control measure these agencies were also co ntacted by the Division in an effort to implement similar sanding practices in the City. Sanding plans were submitted by both the County and Highway Department specifying sanding mediums, routes, and application rates.

8.2.1.7.2 Natural and Uncontrollab le Sources Program

- Natural Events Action Plan

On May 30, 1996, the Environmental Protection Agency (EPA) issued a Natural Events Policy (NEP) which recognized that certain uncontrollable natural events, such as high winds, wildland fires, and volcanic/s eismic activity can result in adverse consequences for the National Ambient Air Quality Standard (NAAQS). The NEP set forth procedures for protecting public health through the development of a Natural Events Action Plan (NEAP) which implements Best

Availa ble Control Measures (BACM) for human- generated particulate emissions in areas where

the PM 10 (particulate matter having a nominal aerodynamic equal to or less than 10 microns) standard may be violated due to these uncontrolled natural events. The NEP also provides that if an approved NEAP is implemented, future air quality exceedances due to uncontrollable natural events may be flagged, and, if demonstrated to be a natural event, not be considered when determining the region’s air quality designation if B ACM measures are being implemented.

A number of Federal Reference or Equivalent PM 10 monitors are located in Wyoming’s Powder River Basin (PRB) at several large mining operations. Some of the monitors have recorded

exceedances of the 24

- hour NAAQS for PM 10 . Each of the monitored exceedances was associated with high winds and blowing dust resulting from prolonged periods of low precipitation and consequential low soil moisture content.

Recognizing the need to protect public health in the Powder River Bas in where measured PM 10 values exceeded the NAAQS because of wind generated dust, in early 2007 the State of Wyoming, with the aid of stakeholders, prepared a Natural Events Action Plan based on EPA Natural Event Policy (NEP) guidance. This plan outlines specific procedures to be taken in response to future high wind events. In short, the purpose of the plan is to:

● Educate the public about the problem;

● Mitigate health impacts on exposed populations during future events; and

● Identify and implement Be st Available Control Measures (BACM) for significant, anthropogenic sources of windblown dust.163 All coal mines in the Wyoming PRB employ Best Available Control Technology (BACT). This

Natural Events Action Plan for the Powder River Basin identifies BACT m easures in place as the result of existing permit requirements, additional potential control measures identified as BACM, and reactionary control measures directed at transient problem sites that may be implemented during Natural Events. Implementation of BACT, BACM, and reactionary control measures will assure that anthropogenic dust emissions from the coal mines in the PRB are controlled to the greatest extent possible. The goal is to protect public health and to minimize exceedances of the

PM 10 NAAQS t hrough the continued implementation of BACT, and implementation of BACM and reactionary control measures.

The Natural Events Action Plan may be accessed at: http://deq.state.wy.us/aqd/NEAP.asp

.

8.2.2 Measures to Mitigate the Impacts of Construction Activities

Chapter 3 of the Wyoming Air Quality Standards and Regulations (WAQSR) establishes limits on the quantity, rate, or concentration of emissions of air pollutants, including any requirements

which limit the level of opacity, prescribe equipment, set fuel specifications, or prescribe operation or maintenance procedures. Specifically, Chapter 3, Section 2(f), prescribes measures to ensure the control of fugitive dust emissions during construction or demolition activities, handling, storage and transporting of materials and agricultural practices. Chapter 3, Section 2(f) was originally adopted by the State of Wyoming on February 22, 1972 . The entire section was restructured on October 29, 1999. Sec tion 2(f) was revised on March 30, 2000 and submitted to EPA on August 13, 2001, then resubmitted on September 12, 2003 as part of the restructuring of the rules. Revisions to Chapter 3 were most recently approved by EPA on July 28, 2004. The

State belie ves these regulations address common construction activities.

Wyoming believes point and area sources of emissions from these regulated sources are in part attributed to impacting regional haze in Wyoming. Wyoming relies on the particulate emission

contr ol measures specified in Chapter 3 to most directly address these sources of fine and coarse particles known to have a minor, but measured, impact on visi bility in Class I areas of the s tate.

8.2.3 Emission Limitations and Schedules of Compliance

The implementation of BART, as described in Chapter 6 , will contain emission limits and schedules of compliance for those sources either installing BART controls or taking F ederally enforceable permit limitations. The four

- factor analysis identifies some additi onal measures that are appropriate for this first Regional Haze Plan. The evaluation of non- BART sources as part of the LTS identifies additional emission reductions and improves visibility by 2018.

8 .2.4 Source Retirement and Replacement Schedules

Par t of this LTS contains an evaluation of non- BA RT sources, described in Sections 8.3.4 and 8.3.5. The Division is not currently aware of any specific scheduled shutdowns, retirements in upcoming years, or replacement schedules, such as planned installation of new control equipment to meet other regulations or routine equipment replacement or modernization. As the Division becomes aware of such actions, they will be factored into upcoming reviews.164 8.2.5 Agricultural and Forestry Smoke Management Techniques

Wyoming Air Quality Standards and Regulations (WAQSR) Chapter 10, Smoke Management, was originally adopted by the State of Wyoming on February 10, 1970. Chapter 10 has been revised several times, most recently becoming an effective State rule on April 5 , 2005. Chapt er 10 was submitted to EPA on April 23, 2004 and is awaiting EPA approval. A smoke management certification was submitted to EPA on November 17, 2005. The last EPA approval was part of the entire restructuring of the rules, approved on July 28, 2004. Chapter 10 is utilized in Wyoming to establish restrictions and requirements on specific burning practices. Section 2 regulates refuse burning; open burning of trade wastes, for salvage operations, for fire hazards, and for firefighting training; and vegetative material open burning. Section 2 includes the permitting of prescribed fires occurring on Federal and State lands, and requires Federal land and State land managers to perform modeling to determine meteorological conditions under which burning can occur and maintain compliance with ambient air quality standards. Section 3 specifically regulates emissions from wood waste burners. Section 4 regulates sources of vegetative burning for the management of air quality emissions and impacts from smoke on public health and visibility.

A Smoke Management Program Guidance Document was developed in November 2004, to assist burners in understanding the requirements and aid in the implementation of Section 4. The intent of Chapter 10 is to provide an equitable and workable program for all burners that is simple to implement and is the least burdensome possible, thereby focusing on the most common situations rather than extreme or isolated circumstances. Burners must comply with all local (city and county), S tate and F ederal laws, regulations and ordinances relating to burning in addition to complying with the regulatory requirements for air quality.

Division staff actively participate in the WRAP Fire Emissions Joint Forum (FEJF), formed to

addres s both policy and technical issues concerning smoke effects that are caused by wildland and agricultural fires on public, tribal, and private lands. The FEJF is guided by the recommendations contained in the GCVTC Final Report and the requirements of the Regional Haze Rule regarding fire emissions and visibility. The FEJF has developed several policies for the WRAP through a stakeholder- based consensus process to assist the WRAP states and tribes in addressing emissions from fire sources. In these policies, the WRAP seeks to provide a consistent framework that states and tribes can use to efficiently develop their individual regional haze implementation plans, long-term strategies, and periodic progress reports.

The WRAP has advanced the following policies developed by the FEJF as viable tools for both Section 308 and 309 states to meet the requirements of the Rule.

● The WRAP Policy for Categorizing Fire Emissions 6 was developed to clarify the complex relationship between what is considered a natural source of fire and what is considered a human-caused source, as acknowledged in the Rule. A methodology to categorize fire emissions as either “natural” or “anthropogenic” is the basis of the Policy;

6 Western Regional Air Partnership, Fire Emissions Joint Forum, Natural Background Task Team, Policy for Categorizing Fire Emissions, November 15, 2001.165 thus providing the foundation for fire’s inclusion in natural background condition values and ultimately, the tracking of reasonable progress.

● The WRAP Policy on Enhanced Smoke Management Programs for Visibility 7 defines the enhanced smoke management program as smoke management efforts that specifically address visibility, thereby, going beyond the EPA Interim Policy and the AAQTF Air Quality Policy specific guidance provided for smoke management programs that address public health and nuisance concerns. The Policy identifies for states/tribes in the WRAP region the elements of an enhanced smoke management program to address visibility effects from all types of fire that contribute to visibility impairment in mandatory Federal

Class I areas.

● The WRAP defines the annual emission goal as a quantifiable value that is used to measure progress each year toward the desired outcome of achieving the minimum

emission increase fro m fire. In the WRAP Policy on Annual Emissions Goals for Fire 8

, the WRAP outlines a process by which states/tribes may establish annual emission goals, based on the utilization of currently available emission reduction techniques, to include in their Regional Haze SIPs.

● It is the position of the WRAP Policy on Fire Tracking Systems 9 that it is necessary to track fire activity information in the WRAP region using a fire tracking system, which will also provide the information essential to create a fire emissions inventor y. The Policy identifies seven essential components of a fire tracking system that represent the minimum spatial and temporal fire activity information necessary to consistently calculate emissions and to meet the requirements of the Rule.

The Air Qualit y Division is required to conduct an Annual Program Evaluation to assess the adequacy of the design, impact and implementation of Wyoming’s Smoke Management Program. The first Evaluation covered the program implementation during calendar years 2005

and 2006.

8.2.6 Enforceability of Wyoming’s Measures

Section 51.308(d)(3)(v)(F) of the Regional Haze Rule requires states to ensure that emission limitations and control measures used to meet reasonable progress goals are enforceable.

Wyoming has ensured t hat all existing emission limitations and control measures , for which the State of Wyoming is responsible, used to meet reasonable progress goals are enforceable at the

State level through the Wyoming Air Quality Standards and Regulations (WAQSR) or State

issued permits. Many of the actions included in the SIP are already federally enforceable.

7 Western Regiona l Air Partnership, Fire Emissions Joint Forum, Enhanced Smoke Management Task Team, WRAP Policy on Enhanced Smoke Management Programs for Visibility, November 12, 2002.

8 Western Regional Air Partnership, Fire Emissions Joint Forum, Annual Emission Goals T ask Team, WRAP Policy on Annual Emission Goals for Fire, DRAFT December 16, 2002.

9 Western Regional Air Partnership, Fire Emissions Joint Forum, WRAP Policy on Fire Tracking Systems, DRAFT December 19, 2002.166 However, BART permit conditions and long- term strategy commitments for the Laramie River Station and the Jim Bridger Power Plant are currently only enforceable at the State level. Once EPA approves this SIP, these measures will be federally enforceable. The BART determinati ons are summarized in Table 6.4 -1 and the long- term strategy commitments can be found in Section

8.3.3.

8.3 Additional Measures in the Long -T erm Strategy

This section of the LTS identifies new measures being proposed by the Division for achieving reasonable progress. These reasonable progress measures will be evaluated and discussed in the next Plan update in 2013.

8.3.1 Future Federal Mobile Programs

A new rule, “Control of Emissions of Air Pollution from Locomotives and Marine CompressionIgnition Engines Less Than 30 Liters per Cylinder”, was signed on March 14, 2008. EPA estimates that by 2030, this program will reduce annual emissions of NO

x by about 800,000 tons and PM emissions by 27,000 tons . Emission reductions are expected to continue as fleet turnover is completed. These standards are intended to achieve these large reductions in emissions through the use of technologies such a s in -cylinder controls, aftertreatment, and low sulfur fuel, perhaps as early as 2011.

In June 2009, EPA announced a rule (Control of Emissions from New Marine CompressionIgnition Engines at or Above 30 Liters per Cylinder) proposing more stringent exha ust emission standards for the largest marine diesel engines used for propulsion on oceangoing vessels (called Category 3 engines). The proposed engine standards are equivalent to the nitrogen oxides limits recently adopted in amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL). The near

- term standards for newly -built engines would apply beginning in 2011. Long-term standards would begin in 2016, and are based on the application of high- efficiency af tertreatment technology. By 2030, this strategy to address emissions from oceangoing vessels is expected to reduce annual emissions of NO

x in the U.S. by approximately 1.2 million tons and particulate matter emissions by about 143,000 tons. When fully im plemented, the coordinated strategy is anticipated to reduce NO

x emissions by 80 percent and PM emissions by 85 percent, compared to the current limits applicable to these engines.

A proposed rule, the Renewable Fuel Standard (RFS2), was signed by Administrator Jackson on May 5, 2009. EPA is proposing that this rule take effect on January 1, 2010; however, this date

is tentative and it could be mid -2010 or January 1, 2011 before this rule becomes final. This rule intends to address changes to the Renewab le Fuel Standard program as required by the Energy Independence and Security Act of 2007 (EISA). The revised statutory requirements establish new specific volume standards for cellulosic biofuel, biomass-based diesel, advanced biofuel,

and total renewable fuel that must be used in transportation fuel each year. The revised statutory requirements also include new definitions and criteria for both renewable fuels and the feedstocks used to produce them, including new greenhouse gas emission (GHG) thresholds for renewable fuels. The regulatory requirements for RFS will apply to domestic and foreign producers and importers of renewable fuel . It is estimated that annual GHG emissions from167 transportation will be reduced by approximately 160 million tons, the equivalent of the removal of 24 million vehicles from the highways. In addition, 36 billion gallons of renewable fuel will displace approximately 11% of gasoline and diesel consumption in 2022. The majority of the reductions are expected to come from redu ced petroleum imports.

8.3.2 Efforts to Address Offshore Shipping

As depicted by PSAT results in Chapter 5, offshore marine vessel emissions contribute to Wyoming Class I areas. Wyoming has no authority to regulate offshore shipping emissions and

must rely upon other states such as California for adoption of regulations. On February 28, 2003 EPA adopted emission standards for new marine diesel engines installed on vessel s flagged or registered in the United States with displacement at or above 30 liter s per cylinder. Also adopted in this rulemaking were additional standards for new engines with displacement at or above 2.5 liters per cylinder but less than 30 liters per cylinder. This rule established a deadline of April 27, 2007 for EPA to promulgate a second set of emission standards for these engines. Because much of the information necessary to develop more stringent Category 3 marine diesel engines standards has become available only recently, a new deadline for the rulemaking to consider the

next tier of Category 3 marine diesel engine standards has been set for December 17, 2009. On December 7, 2007, EPA announced an advance notice of proposed rulemaking regarding the above-referenced standards, first set in 2003. The advanced notice of proposed rulemaking stated that EPA was considering standards for achieving large reduc tions in oxides of nitrogen (NO

x ) and particulate matter (PM) through the use of technologies such as in-cylinder controls, aftertreatment, and low sulfur fuel, starting as ear ly as 2011.

On July 24, 2008, the State of California adopted new strict regulations for marine vessels within

24 miles of shore. The Division expects that implementation of these new regulations for marine vessels will have benefits in Wyoming.

In Oc tober 2008, Member States of the International Maritime Organization (IMO) adopted new international standards for marine diesel engines and their fuels (2008 Amendments to MARPOL Annex VI) that apply globally, and establishes additional, more stringent emission requirements for ships that operate in specially- designated coastal areas where air quality problems are acute.

Und er the new global standards, NO

x emissions will be reduced, and the fuel sulfur cap will drop to 5,000 ppm in 2020 (pending a fuel availability review in 2018). Under the new geographic standards, ships operating in designated areas will be required to use engines that meet the most

advanced tech nology- forcing standards for NO

x emissions, and to use fuel with sulfur content at or below 1,000 ppm.

On March 27, 2009, the United States submitted a joint proposal with Canada to the IMO to designate specific areas of our coastal waters as an Emission Control Area (ECA). Compared to fuels used in ships today, ECA standards will lead to a 96 percent reduction in sulfur in ships’ fuels, as well as a cut in emiss ions of PM by 85 percent and NO

x by 80 percent. To achieve these reductions, ships must use fuel with no more than 1,000 parts per million sulfur beginning in 2015, and new ships will have to use advanced emission control technologies beginning in

2016.168 8.3.3 Long- Term Control Strategies for BART Facilities

In addition to the control str ategies identified in Chapter 6 ( Best Availa ble Retrofit Technology (BART) ) as BART determinations , the following requirements will be established through permit conditions or orders from the Environmental Quality Council for the individual BART

facilities listed below:

Laramie River Station :

On March 8, 2010, Basin Electric Power Cooperative appeale d the BART permit for the Laramie River Station before the Wyoming Environmental Quality Council (EQC). The Department of Environmental Quality entered into a settlement agreement on November 16, 2010 with Basin Electric Power Cooperative to modify the BA RT permit. On December 8, 2010, the Division held a State Implementation Plan (SIP) Hearing on Regional Haze. The SIP hearing was held in Cheyenne, Wyoming at the Laramie County Library, 2200 Pioneer Avenue. At that time, the Division collected public comment on the Regional Haze SIP revisions.

After carefully considering all comments on revisions to the State Implementation Plan to address Regional Haze, the Division has determined that the following requirements for further

NO

x reduction taken from the Settlement Agreement Filed November 16, 2010 before the Wyoming EQC and incorporated into the EQC Order approving the Settlement, shall establish

the NO

x reduction requirements under the Long- Term Strategy of the Wyoming Regional Haze

SIP for three units at Laramie River Station with respect to NO

x and NO

x only.

1. Total NO

x emissions from Laramie River Station Units 1, 2 and 3 shall be further reduced to a plant-wide emission limit of 12,773 tons of NO

x per year by December 31, 2017 and continuing there after, unless change d pursuant to new regulatory or permit requirements.

2. Basin Electric Power Cooperative shall submit to the Division a permit application for the 12,773 ton plant- wide NO

x emission limit at the Laramie River Station by December 31, 2015.

Jim Bridger Power Plant (Units 1 and 2):

With respect to Bridger Units 1 and 2, PacifiCorp shall: (i) install SCR; (ii) install alternative

add -on NO

x control systems; or (iii) otherwise reduce NO

x emis sions not to exceed a 0.07

lb/MM Btu 30-day rolling average NO

x emissions rate. These installations shall occur, and/or this emission rate will be achieved, on Unit 2 prior to December 31, 2021 and Unit 1 prior to December 31, 2022. These installations shall occur, and/or this emission rate will be ac hieved, in conjunction with PacifiCorp’s planned overhaul schedule for these units and pursuant to a construction or other permit application to be submitted by PacifiCorp to AQD no later than December 31, 2017.169 Jim Bridger Power Plant (Units 3 and 4):

With respect to Bridger Units 3 and 4, PacifiCorp shall: (i) install SCR; (ii) install alternative

add -on NO

x control systems; or (iii) otherwise reduce NO

x emissions to achieve a 0.07

lb/MM Btu 30-day rolling average NO

x emissions rate. These installati ons shall occur, and/or this emission rate will be achieved, on Unit 3 prior to December 31, 2015 and Unit 4 prior to December 31, 2016. These installations shall occur, and/or this emission rate will be achieved, in conjunction with PacifiCorp’s planned overhaul schedule for these units and pursuant to a construction or other permit application to be submitted by PacifiCorp to AQD no later than December 31, 2012.

8.3.4 Evaluation of Control Strategies for Sources Identified in the Reasonable Progress
- Four -Factor Analysis

The previous chapter evaluated certain non-BART sources through a four- factor analysis for additional controls, as was required by the Federal Regional Haze Rule. This evaluation was limited, in that no guidance was provided for identifying “significant sources”, and no contribution to visibility impairment thresholds were established (a potential fifth factor). The Division applied a “Quantity over Distance” (Q/D) process for screening out the most significant stationary source contributors, but that was only the first step in identifying control options. The Air Quality Administrator cannot, per Wyoming Statute 35 -11-202, establish emission control requirements except through State rule or regulation. Furthermore, the W yoming statute requires the Administrator to consider the character and degree of injury of the emissions involved. In this case, visibility modeling would be required to assess the degree of injury caused by the

emissions. Mode ling is not available at this time to determine impacts from emission reduction. The State believes it has taken a strong and reasonable first step in identifying potential contributors to visibility impairment, and that the next step of creating an appropriate rule or regulation will be accomplished in the next SIP revision. The visibility progress was designed as a long-term program going out to 2064.

8.3.5 Oil and Gas

As discussed in Section 7.3.5, oil and gas production, which is not limited to just one area of Wyoming, is a large, important, and critical component of the S tate economy. However, the sources associated with oil and gas production emit NO

x , and to a lesser extent, PM. An extensive fleet of field equipment and an array of processing plants operate continuousl y conducting exploration, production, and gathering activities. Exploration and d rilling includes seismic studies, engineering, well testing, drilling operations, and transportation of personnel or equipment to and from sites. Oil and gas production includes operation, maintenance, and servicing of production properties, including transportation to and from sites. Sources include turbines, drill rig engines, glycol dehydrators, amine treatment units, flares and incinerators.

Understanding the sources and volume of emissions at oil and gas production sites is key to recognizing the impact that these emissions have on visibility. To better understand the emissions from these sources, the WRAP instituted a three- phase project. One of the issues was170 to qua ntify emission inventories from stationary and mobile equipment operated as part of oil and gas field operations.

Phase I, which was completed in 2005, was an emission inventory project that estimated regional emissions from oil and gas field operations. Phase II, completed in late 2007, was an effort to more fully characterize the oil and gas field operations emissions. Phase III which began in late 2007 with the Independent Petroleum Association of Mountain States (IPAMS) in conjunction

with WRAP initi ating a regional oil and gas emission inventory project is underway. The Division cannot complete the evaluation of oil and gas on visibility until this study has been completed.

8.3.6 Projection of the Net Effect on Visibility

The WRAP has projected the net effect on visibility from emission reductions by point, area and mobile sources throughout the WRAP region through 2018. The first emission projection inventory was compiled in 2006. The inventory was revised in 2007 to make preliminary

evaluation s of reasonable progress towards Class I areas visibility goals. The 2007 inventory focused on the most significant point and area sources of visibility impairing pollution in states and Native American Reservations. This effort included updating project ions of electric generating units and incorporating known and presumed BART emission levels. Then, in the spring of 2009, the WRAP once again updated emission inventory projections for point and area sources in the WRAP region to give the most current ass essment of reasonable progress towards visibility goals. Again, the updated projection inventory reflected new information about BART determinations and projection of future fossil fuel plants needed to achieve 2018 F ederal electrical generation demands. More information on the specifics of the most recent emission inventory work collected for the 2018 visibility projections is contained in Chapter 4 of the Wyoming TSD in the April 29 , 2009 ERG Technical Memorandum.

Chapter 5 of this Plan shows the specific results of the CMAQ modeling which was used to make all projections of visibility. Those results show anthropogenic emissions sources generally declining across the West through 2018. However, natural sources such as wildfires and dust, international sources in Mexico and Canada, global transport of emissions and off shore shipping in the Pacific Ocean all appear to offset improvements in visibility from controls on manmade sources. In spite of the large number of growing uncontrollable sources in the WRAP region, however, Wyoming does see a net visibility improvement at the Wyoming Class I areas through 2018. The net effect of all of the reductions in the WRAP region, known at the time of the most

recent model run is demonstrated in the WRAP Class I Summary Tables shown below for each of the Class I areas in Wyoming.171 Table 8.3.6-1. Class I Area Visibility Summary for YELL2 on 20% Worst Days

Class I Area Visibility Summary: Grand Teton NP, WY: Red Rock Lakes
NWRW, MT: Teton W, WY: Yellowstone NP, WY
Visibility Conditions: Worst 20% Days

RRF Calculation Method: Specific Days (EPA)

Emissions Scenarios: 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

Monitored Estimated Projected

2000

- 04

Baseline

Condit ions 2064

Natural

Conditions 2018

Uniform

Rate of Progress

Target 2018 Projected Visibility

Conditions Baseline

to 2018 Change In

Statewide

Emissions Baseline

to 2018 Change In

Upwind Weighted

Emissions 2 Baseline to 2018 Change

In Anthropogenic Upwind Weig hted

Emissions 2

(Mm

- 1) (Mm

- 1) (Mm

- 1) 1 (Mm

- 1) (tons / %) (%) (%)

Sulfate 4.26 0.76 3.35 3.71 - 22,794

- 26%

- 32%

- 15%

Nitrate 1.77 0.63 1.5 1.36 - 39,861

- 26%

- 34%

- 14%

Organic

Carbon 13.48 4.61 11.02 12.87 - 730

- 4%

- 29%

- 3%

Elemental

Carbon 2.48 0.43 1.97 2.2 - 1,217

- 11%

- 50%

- 15%

Fine Soil 0.95 1.02 0.97 1.04 5,223

14% 25% 31%

Coarse

Material 3 2.58 2.99 2.67 Not Applicable 13,394

19% 42% 27%

Sea Salt 3 0.02 0.03 0.02

Not Ap plicable

Total Light

Extinction 34.55 19.47 30.25 32.77

Deciview 11.76 6.44 10.52 11.23

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined. 2) Results based on Weighted Emissions Potential analysis using the 2000

- 0 4 Baseline (plan02d) & 2018 PRPb (prp18b)

emissions scenarios. 3) Visibility projections not available due to model performance issues. (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )172 Table 8.3.6-2. Class I Area Visibility Summary for NOAB1 on 20% Worst Days

Class I Area Visibility Summary: North Absaroka W, WY: Washakie W, WY
Visibility Conditions: Worst 20% Days

RRF Calculation Method: Spe cific Days (EPA)

Emissions Scenarios: 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

Monitored Estimated Projected

2000

- 04

Baseline

Conditions 2064

Natural

Conditions 2018

Uniform

Rate of Progress

Target 2018 Projected Visibility

Conditions Baseline

to 2018 Change In

Statewide

Emissions Baseline

to 2018 Change In

Upwind Weighted

Emissions 2 Baseline to 2018 Change

In Anthropogenic Upwind Weighted

Emissions 2

(Mm

- 1) (Mm

- 1) (Mm

- 1) 1 (Mm

- 1) (tons / %) (%) (%)

Sulfate 4.87 0.81 3.8 4.5 - 22,794

- 11%

- 12%

- 15%

Nitrate 1.61 0.75 1.4 1.29 - 39,861

- 22%

- 28%

- 14%

Organic

Carbon 11.64 4.62 9.75 11 - 730

- 5%

- 21%

- 3%

Elemental

Carbon 1.86 0.44 1.51 1.59 - 1,217

- 17%

- 47%

- 15%

Fine Soil 0.85 0.92 0.8 6 0.95 5,223

17% 28% 31%

Coarse

Material 3 2.91 3.44 3.03 Not Applicable 13,394

20% 35% 27%

Sea Salt 3 0.01 0.03 0.01

Not Applicable

Total Light

Extinction 32.74 20.02 29.21 31.25

Deciview 11.45 6.83 10.38 11

1) 2018 U niform Rate of Progress Target for Best 20% Days is not defined. 2) Results based on Weighted Emissions Potential analysis using the 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

emissions scenarios. 3) Visibility projections not availab le due to model performance issues. (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )173 Table 8.3.6-3. Class I Area Visibility Summary for BRID1 on 20% Worst Days

Class I Area Visibility Summary: Bridger W, WY: Fitzpatrick W, WY
Visibility Conditions: Worst 20% Days

RRF Calculation Method: Specific Days (EPA)

Emissions Scenarios: 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

Monitored Estimate d Projected

2000

- 04

Baseline

Conditions 2064

Natural

Conditions 2018

Uniform

Rate of Progress

Target 2018 Projected Visibility

Conditions Baseline

to 2018 Change In

Statewide

Emissions Baseline

to 2018 Change In

Upwind Weighted

Emissions 2 Baseline to 2018 Change

In Anthropogenic Upwind Weighted

Emissions 2

(Mm

- 1) (Mm

- 1) (Mm

- 1) 1 (Mm

- 1) (tons / %) (%) (%)

Sulfate 4.99 0.82 3.89 4.06 - 22,794

- 31%

- 32%

- 15%

Nitrate 1.43 0.79 1.27 1.24 - 39,861

- 19%

- 21%

- 14%

Organic

Carbon 1 0.55 4.64 8.98 10.31 - 730

- 4%

- 18%

- 3%

Elemental

Carbon 1.99 0.39 1.59 1.77 - 1,217

- 17%

- 50%

- 15%

Fine Soil 1.1 1.07 1.1 1.19 5,223

13% 23% 31%

Coarse

Material 3 2.51 2.67 2.55 Not Applicable 13,394

16% 39% 27 %

Sea Salt 3 0.04 0.04 0.04

Not Applicable

Total Light

Extinction 31.6 19.42 28.23 30.12

Deciview 11.12 6.45 10.03 10.63

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined. 2) Results based on Weighted Emissio ns Potential analysis using the 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

emissions scenarios. 3) Visibility projections not available due to model performance issues. (WRAP TSS

- http://v ista.cira.colostate.edu/tss/ )174 Table 8.3.6-4. Class I Area Visibility Summary for YELL2 on 20% Best Days

Class I Area Visibility Summary: Grand Teton NP, WY: Red Rock Lakes NWRW, MT: Teton W, WY: Yellowstone NP, WY
Visibility Conditions: Best 20% Days

RRF Calculation Method: Specific Days (EPA)

Emissions Scenarios: 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

Monitored Estimated Projected

2000

- 04

Baseline

Conditions 2064

Natural

Condi tions 2018

Uniform

Rate of Progress

Target 2018 Projected Visibility

Conditions Baseline

to 2018 Change In

Statewide

Emissions Baseline to

2018 Change In

Upwind Weighted

Emissions 2 Baseline to 2018 Change

In Anthropogenic Upwind Weighted

Emissions 2

(M m

- 1) (Mm

- 1) (Mm

- 1) 1 (Mm

- 1) (tons / %) (%) (%)

Sulfate 1.47 0.33 Not Applicable 1.43 - 22,794

- 20%

- 26%

- 15%

Nitrate 0.72 0.29 Not Applicable 0.57 - 39,861

- 27%

- 36%

- 14%

Organic

Carbon 1.13 0.48 Not Applicable 1.1 - 730

- 3%

- 28%

- 3%

Elemental

Carbon 0.31 0.07 Not Applicable 0.22 - 1,217

- 10%

- 50%

- 15%

Fine Soil 0.1 0.08 Not Applicable 0.14 5,223

13% 25% 31%

Coarse

Material 3 0.24 0.2 Not Applicable

Not Applicable 13,394

18% 44% 27%

Sea Salt 3 0.01 0 Not Applicable

Not Applicable Total Light

Extinction 12.99 10.45 Not Applicable 12.71

Deciview 2.58 0.43 Not Applicable 2.36

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined. 2) Results based o n Weighted Emissions Potential analysis using the 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

emissions scenarios. 3) Visibility projections not available due to model performance issues. (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )175 Table 8.3.6-5. Class I Area Visibility Summary for NOAB1 on 20% Best Days

Class I Area Visibility Summary: North Absaroka W, WY: Washakie W, WY
Visibility Cond itions: Best 20% Days

RRF Calculation Method: Specific Days (EPA)

Emissions Scenarios: 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

Monitored Estimated Projected

2000

- 04

Baseline

Conditions 2064

Natural

Conditions 2018

Uniform

Rate o f Progress

Target 2018 Projected Visibility

Conditions Baseline

to 2018 Change In

Statewide

Emissions Baseline

to 2018 Change In

Upwind Weighted

Emissions 2 Baseline to 2018 Change

In Anthropogenic Upwind Weighted

Emissions 2

(Mm

- 1) (Mm

- 1) (Mm

- 1) 1 (Mm

- 1 ) (tons / %) (%) (%)

Sulfate 1.11 0.27 Not Applicable 1.1 - 22,794

- 22%

- 24%

- 15%

Nitrate 0.37 0.23 Not Applicable 0.33 - 39,861

- 28%

- 34%

- 14%

Organic

Carbon 0.8 0.46 Not Applicable 0.77 - 730

- 6%

- 23%

- 3%

Elemental

Carbon 0.16 0.05 Not Applicable 0.14 - 1,217

- 21%

- 50%

- 15%

Fine Soil 0.12 0.11 Not Applicable 0.15 5,223

16% 26% 31%

Coarse

Material 3 0.71 0.49 Not Applicable

Not Applicable 13,394

19% 40% 27%

Sea Salt 3 0.02 0.02 Not Applicable

Not Applicable Total Light

Extinction 12.28 10.61 Not Applicable 12.22

Deciview 2.02 0.58 Not Applicable 1.97

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined. 2) Results based on Weighted Emissions Potential analysis using the 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

emissions scenarios. 3) Visibility projections not available due to model performance issues. (WRAP TSS

- http://vist a.cira.colostate.edu/tss/ )176 Table 8.3.6-6. Class I Area Visibility Summary for BRID1 on 20% Best Days

Class I Area Visibility Summary: Bridger W, WY: Fitzpatrick W, WY
Visibility Conditions: Best 20% Days

RRF Calculation Method: Specific Days (EPA)

Emissions Scenarios: 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

Monitored Estimated Projected

2000

- 04

Baseline

Conditions 2064

Natural

Conditions 2018

Uniform

Rate of Progress

Target 2018

P rojected Visibility

Conditions Baseline

to 2018 Change In

Statewide

Emissions Baseline

to 2018 Change In

Upwind Weighted

Emissions 2 Baseline to 2018 Change

In Anthropogenic Upwind Weighted

Emissions 2

(Mm

- 1) (Mm

- 1) (Mm

- 1) 1 (Mm

- 1) (tons / %) (%) (%)

Sulfate 1.45 0.28 Not Applicable 1.35 - 22,794

- 31%

- 33%

- 15%

Nitrate 0.43 0.25 Not Applicable 0.41 - 39,861

- 21%

- 25%

- 14%

Organic

Carbon 0.8 0.41 Not Applicable 0.8 - 730

- 5%

- 23%

- 3%

Elemental

Carbon 0.36 0.08 Not Ap plicable 0.29 - 1,217

- 20%

- 53%

- 15%

Fine Soil 0.09 0.07 Not Applicable 0.12 5,223

13% 23% 31%

Coarse

Material 3 0.25 0.2 Not Applicable

Not Applicable 13,394

16% 42% 27%

Sea Salt 3 0.01 0.01 Not Applicable

Not Applicab le Total Light

Extinction 12.38 10.3 Not Applicable 12.22

Deciview 2.1 0.28 Not Applicable 1.97

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined. 2) Results based on Weighted Emissions Potential analysis using th e 2000

- 04 Baseline (plan02d) & 2018 PRPb (prp18b)

emissions scenarios. 3) Visibility projections not available due to model performance issues. (WRAP TSS

- http://vista.cira.colostate.edu/tss/ )177 Since the Regional Haze process has proved to be much more complicated than the rule writers ever imagined, the entire process has taken longer than originally estimated. While most east coast states accepted EPA’s determination that CAIR sa tisfied BART for electric generating units, some western states are still going through the difficult case

- by

- case BART determinations for each EGU. As a result, the WRAP was not able to model all of the emission reductions from

BART and S tate long

- term strategies in the most r ecent modeling effort. In the State of Wyoming, significant additional NO

x reductions will be made at the completion of the BART and long- term strategy. The overall cumulative NO

x reductions from Wyoming sources over

ti me are demon strated in the figure below. Any additional future modeling will most likely demonstrate additional progress towards the 2018 visibility goals.

Figure 8.3.6-7. Additional Cumulative NO

x Reductions From Wyoming Sources178 

### CHAPTER 9

ONGOING MONITORING AND EMISSION INVENTORY STRATEGY

The State of Wyoming will rely upon a Regional Planning Organization’s provision of adequate technical support to meet its commitment to conduct the analyses necessary to meet the requirements of 51.308(d)(4).

The State of Wyoming will depend on the Inter-Agency Monitoring of P ROtected V isual Environments (IMPROVE) monitoring program to collect and report aerosol monitoring data for long- term reasonable progress tracking as specified in 40 CFR 51.308(d)(4) of the Regional Haze Rule (RHR). Because the RHR is a long

- term tracking program with an implementation period nomina lly set for 60 years, the Division expects that the IMPROVE program will provide data based on the following goals:

1) Maintain a stable configuration of the individual monitors and sampling sites, and stability in network operations for the purpose of continuity in tracking reasonable progress trends; 2) Assure sufficient data capture at each site of all visibility

- impairing species; 3) Comply with EPA quality control and assurance requirements; and 4) Prepare and disseminate period ic reports on IMPROVE program operations.

The State of Wyoming is relying on the IMPROVE program to meet these monitoring operation and data collection goals, with the fundamental assumption that network data collection operations will not change, or if changed, will remain directly comparable to those operated by the IMPROVE program during the 2000-2004 RHR baseline period. Technical analyse s and

reason able progress goals in this Implementation P lan for Regional Haze are based on data from

these sites. As such, the State asks that the IMPROVE program identify potential issues affecting RHR implementation tre nds and/or notify the State before changes in the IMPROVE program affecting a RHR tracking site are made.

Further, the State of Wyoming notes that the human resources to operate these monitors are provided by Federal Land Management agencies. Beyond that in-kind contribution, resources for operation and sample analysis of a complete and representative monitoring network of these long- term reasonable progress tracking sites by the IMPROVE program are a collaborative

respons ibility of EPA, states, tribes, and FL Ms and the IMPROVE program s teering committee. The State of Wyoming will collaborate with the EPA, FLMs, other states, tribes, and the IMPROVE committee to assure adequate and representative data collection and reporting by the IMPROVE program.179 Figure 9-1. Links to Site Loc ations and Monitors

Site

Name Site Location Link

BRID1 VIEWS

WRAP TSS

IMPROVE http://vista.cira.colostate.edu/views/Web/SiteBrowser/SiteBrowser.aspx http://vista.cira.colostate.edu/TSS/Tools/AOI.aspx http://vista.cira.colostate.edu/Datawarehouse/IMPROVE/Data/Photos/BRID/start.htm

NOAB1 VIEWS

WRAP TSS http://vista.cira.colostate.edu/views/Web/SiteBrowser/SiteBrowser.aspx http://vista.cira.colostate.edu/TSS/Tools/AOI.aspx

YELL2 VIEWS

WRAP TSS

IMPROVE http://vista.cira.colostate.edu/views/Web/SiteBrowser/SiteBrowser. aspx http://vista.cira.colostate.edu/TSS/Tools/AOI.aspx http://vista.cira.colostate.edu/Da tawarehouse/IMPROVE/Data/Photos/YELL/start.htm

Pursuant to 40 CFR 51.308(d)(4)(i), the State of Wyoming depends on the following IMPROVE program-operated monitors at the following sites for tracking RHR reasonable progress:

Table 9-1. The Wyoming IMPROVE Monitoring Network

Site Code Class I Area Sponsor Elevation (MSL) Start Date

BRID1 Bridger Wilderness Fitzpatrick Wilderness USFS 2627 m

8619 ft 3/2/1988

NOAB1 North Absaroka Wilderness

Washakie Wilderness USFS 2483 m

8146 ft 1/25/2000

YEL L2 Grand Teton National Park

Teton Wilderness

Yellowstone National Park NPS 2425 m

7956 ft 7/1/1996

In accordance with provisions of 40 CFR 51.308(d)(4)(ii), t he State of Wyoming will use data reported by the IMPROVE program as part of the regional technical support analysis tools found at the Visibility Information Exchange Web System (VIEWS) and the Technical Support System (TSS), as well as other analysis tools and efforts sponsored by a Regional Planning Organization. Wyoming will participate in the ongoing regional analysis activities of a Regional Planning Organization to collectively assess and verify the progress toward reasonable progress goals, also supporting interstate consult ation as the RHR is impleme nted, and collaborate with members of a Regional Planning Organization to ensure the continued operation of these technical support analysis tools and systems.

Wyoming may conduct additional analyses as needed.

The State of Wyoming will depend on the routine, timely reporting of haze monitori ng data by the IMPROVE program for the reasonable progress tracking sites to the EPA air quality data

systems, VIEWS and TSS as set forth in 40 CFR 51.308(d)(4)(iv) . The State of Wyo ming will

collaborate with members of a Regional Planning Organization to ensure the continued operation of these technical support analysis tools and systems.

Per requirements of 40 CFR 51.308(d)(4)(v), the State of Wyoming has prepared a statewide inventory of emissions that can reasonably be expected to cause or contribute to visibility impairment in Federal Class I areas. Chapter 4 of this P lan summarizes the emissions by pollutant and source category.180 The State of Wyoming commits to updating statewide emissions periodically. The updates will be used for state tracking o f emission changes, trends, and input into a Regional Planning Organization’s evaluation of whether reasonable progress goals are b eing achieved and other regional analyses. The inventories will be updated every three years on the same schedule as the

eve ry three -year reporting required by EPA’s Consolidated Emissions Reporting Rule

.

As a member of a Regional Planning Organization, t he St ate of Wyoming will use the Regional Planning Organization-sponsored data system(s) to store and access emission inventory data for the region. The State of Wyoming will also depend upon and participate in additional periodic

collective emissio ns inventory efforts by a Regional Planning Organization. Further, the State of Wyoming will dep end on and use the capabilities o f a Regional Planning Organizationsponsored modeling center to simulate the air quality impacts of emissions for haze and other related air quality planning purposes. The State of Wyo ming will collaborate with members of a Regional Planning Organization to ensure the continued operation of these technical support analysis tools and systems.

T he State of Wyoming , in accordance with provisions of 40 CFR 51.308(d)(4)(vi), will track

data related to RHR haze plan implementati on for sources for which the State has regulatory authority, and will depend on the IMP ROVE program and a Regional Planning Organizationsponsored collection and analysis efforts and data support systems for monitoring and emissions inventory data, respectively. To ensure the availabilit y of data and analyses to report on visibility conditions and progress toward Class I area visibility goals, the State of Wyo ming will

collaborate with members of a Regional Planning Organization to ensure the continued operation

of the IMPROVE program and Regional Planning Organization-sponsored technical support analysis tools and systems.181 

### CHAPTER 10

COMPREHENSIVE PERIODIC IMPLEMENTATION PLAN REVISIONS

40 CFR 51.308(f) requires the Division to revise its Regional Haze Implementation P lan and

submit a P lan revision to the USEPA by July 31, 2018 and every ten years thereafter. In accordance with the requirements list ed in Section 51.308(f) of the F ederal rule for regional haze, Wyoming commits t o revising and submitting this Regional Ha ze I mplementation P lan by July 31, 2018 and every ten years thereafter.

In addition, 51.308(g) requires periodic reports evaluating progress towards the reasonable progress goals established for each mandatory Class I area. In accordance with the require me nts listed in 51.308(g) of the F ederal rule f or regional haze, the Division commits to submitting a report on reasonable progress to the USEPA every five years following the initial submittal of the SIP. The report will be in the form of a SIP revision. The reasonable progress report will evaluate the progress made towards the reasonable progress goal for each mandatory Class I area located within Wyoming and in each mandatory Class I area located outside Wyoming which may be affected by emissions from within Wyoming.

The requirements listed in 51.308(g) include the following:

1. A description of the status of implementation of all measures included in the implementation plan for achieving reasonable progress goals for mandatory Class I

Federal areas b oth within and outside the state;

2. Summary of emission reductions achieved thus far;

3. Assessment of changes in visibility conditions at each Class I area (current vs. baseline), expressed as 5

- year averages of annual values for least impaired and mos t impaired days;

4. Analysis of emissions changes over the 5-year period, identified by source or activity, using the most recent updated emissions inventory;

5. Analysis of any significant changes in anthropogenic emissions in or out of the s tate
which have impeded progress;

6. Assessment of the sufficiency of the implementation plan to meet reasonable progress goals;

7. Review of the State’s visibility monitoring strategy and any modifications to the strategy

as necessary.182 

### CHAPTER 11

WYOMING REG IONAL HAZE S IP DEVELOPMENT AND

CONSULTATION PROCESS

11.1 State to State Consultation

Pursuant to 40 CFR Section 51.308(d)(iv), the State of Wyoming consulted with other states through a regional planning organization, the Western Regional Air Partnership (WRAP), in developing reasonable progress goals. The WRAP is a collaborative effort of tribal governments, State governments and various F ederal agencies to implement the Grand Canyon Visibility Transport Commission's recommendations and to develop the technical and policy tools needed by western states and tribes to comply with the U.S. EPA’ s regional haze regulations. The WRAP is administered jointly by the Western Governors’ Association and the

National Tribal Environmental Council. WRAP activities are conducted by a network of committees and forums composed of WRAP members and stakeholders who represent a wide range of viewpoints. The WRAP recognizes that residents have the most to gain from improved visibility and that many solutions are best implemented at the local, state, tribal or regional level with public participation. The following states: Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming have agree d to work together to address regional haze in the W estern United States. The goals, objectives, management and decision making structure of the WRAP are described in Work Plans and a Strategic Plan provided in Chapter 1 of the Wyoming TSD.

This consultation effort began with all states in the WRAP region contributing information to a technical support system (TSS) which allows all states to better understand the causes of haze and the levels of contribution from all sources to each Class I area. This project has involved many hours of consultation between states on regional emission inventories, monitoring and modeling to determine the causes of visibility impairment in each mandatory Class I Federal area in the regional planning area. WRAP forums involved in the technical consultation between

states are as follows:

Air Pollution Prevention Forum Mobile Sources Forum

Dust Emissions Forum Sources In and Near Class I Areas Forum Economic Analysis Forum Stationary Sources Forum

Emissions Forum Technical Analysis Forum

Fire Emissions Forum

The next step in state consultation in the development of reasonable progress goals was through the Implementation Work Group (IWG) of the WRAP. The State of Wyoming participated in the IWG which took the products of the technical consultation process discussed above and developed a process for establishing reasonable progress goals in the W estern Class I areas. A description of that process and the determination of reasonable progress goals for each of the

Class I areas in the State of Wyoming is described in Chapter 7 . The following states have agreed to work together through the IWG in the development of reasonable progress goals: Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming.183 Opportunities for consultation on development of reasonable progress goals provided through the

WRAP Implementation Work Group have been docume nted in calls listed on the Implementation Work Group section of the WRAP website at: http://www.wrapair.org/forums/iwg/meetings.html

.

Pursuant to 40 CFR Section 51.308(d)(iv), the State of Wyoming also gave opportunity for neighbo ring states to co mment on the State of Wyoming ’s reasonable progress goals for each

Class I area located within the s tate. Opportunity for comment from other states was offered through a public hearing on the State Implementation Plan (SIP), held in accordance with 40 CFR Section 51.102. The following states in the WRAP region were notified of the SIP public hearing: Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, Nevada, and Hawaii . The following states in the neighboring Central States Regional Planning Organization (CENRAP) were notified of the SIP public hearing: Iowa, Kansas, Minnesota, Missouri, Nebraska, Oklahoma, and Texas. Consultation correspondence between Wyoming and other states will be included in Chapter 11 of the Wyoming TSD. Comments were received from the following states, on the State of Wyoming ’s reasonable progress goals for Class I areas located within the State of Wyoming

.

The State of Wyoming took the fo llowing actions to resolve the disagreement:

The State of Wyoming did not receive any comments from other states indicating disagreement on the reasonable progress goals established for the following Class I areas: Bridger Wilderness, Fitzpatrick Wildern ess, Grand Teton National Park, North Absaroka Wilderness, Teton Wilderness, Washakie Wilderness, and Yellowstone National Park.

Pursuant to 40 CFR 51.308(d)(3)(i), the State of Wyoming has participated in regional planning

and coordination with other s tates in developing emission management strategie s if emissions from within the state contribute to visibility impairment in a mandatory Cl ass I Federal area outside the state, or if emissions from another state, regional planning organization, country, tribal area, or offshore location contribute to visibility impairment in any C lass I Federal area

within the s tate. This participation was through the Western Regional Air Partnership (WRAP). A more detailed description of the goals, objectives, management, and decision-making structure of the WRAP has been included in Work Plans and a Strategic Plan provided in Chapter 1 of the Wyoming TSD. The following WRAP forums have provided consultation opportunities between states on emission management strategies:

Air Pollution Prevention Forum Mobile Sources Forum

Dust Emissions Forum Sources In and Near Class I Areas Forum Economic Analysis Forum Stationary Sources Forum

Emissions Forum Technical Analysis Forum

Fire Emissions Forum

Opportunities for consultation on emission strategies provided through the WRAP have been

d ocumented in calls and meetings on the WRAP website at: http://www.wrapair.org/cal/calendar.php

.184 A description of the selected emission management strategies for the State of Wyoming is described in Chapter 8 of this Plan

. The State of Wyoming views the development of coordinated emission management strategies to be a long- term commitment, and therefore, the State of Wyoming agre es to continue to participate in the WRAP or an alternative Regional Planning Organization in developing coordinated emission management strategies for SIP

revisions in 2013 and 2018.

Pursuant to 40 CFR 51.308(h)(2), the State of Wyoming has determined t his first State Implementation P lan is adequate to ensure reasonable progress for the first planning period of the regional haze long-term planning effort which extends out to the year 2064. While emissions

from sour ces outside of the State of Wyoming hav e resulted in a slower rate of improvement in visibility than the rate that would be needed to attain natural conditions by 2064, most of these emissions are beyond the control of any state in the regional planning area of the WRAP. The emission sources include: emissions from outside the WRAP domain; emissions from Canada and Mexico; emissions from wildfires and windblown dust; and emissions from offshore shipping. A more detailed description and quantification of these uncontro lled emissions is

included in t he Source Apportionment and Regional Haze Modeling chapter of this SIP. Additional strategies to address emissions beyond the control of any state in the WRAP under the juris diction of EPA are discussed in the Long- Term Strategy chapter of this SIP

.

Through the WRAP consultation process the State of Wyoming has reviewed and analyzed the contributions from other states that reasonably may cause or contribute to visibility impairment in Wyoming’s Class I areas. Wyoming acknowledges that the l ong- term strategies adopted by Colorado, South Dakota, and Idaho in their SIPs and approved by EPA will include emission reductions from a variety of sources that will reduce visibility impairment in Wyoming ’s Class I

areas.185 Figure 1 1.1-1. Regional Planning Organizations

11.2 State and Federal Land Manager Coordination

40 CFR Section 51.308(i) of the Regional Haze Rule requires coordination between states and

the Federal La nd Managers (FLMs). Wyoming has provided agency contact s to the FLMs as required under 51.308(i)(1). During the development of this Plan, the FLMs were consulted in accordance with the provisions of 51.308(i)(2).

Numerous opportunities were provided by the Western Regional Air Partnership for FLMs to partici pate fully in the development of technical documents developed by the WRAP and included in this Plan. This included the ability to review and comment on these analyses, reports, and policies. A summary of WRAP-sponsored meetings and conference calls is provided on the WRAP website at: http://www.wrapair.org/cal/calendar.php

.

The State of Wyoming has provided an opportunity for consultation, in person and at least 60 days prior to holding any public hearing on the SIP. As required by 40 CFR Section 51.308(i)(3), the FLM comments and State responses, as well as email exchanges from the FLM community to the Division explaining their review preferences of the SIP, will be included in Chapter 11 of th e Wyoming TSD.

40 CFR Sections 51.308(f- h) establish requirements and timeframes for states to submit periodic SIP revisions and progress reports that evaluate progress toward the reasonable progress goal for each Class I area. As required by 40 CFR Sect ion 51.308(i)(4), Wyoming will continue to186 coordinate and consult with the FLMs during the development of the se future progress reports and Plan revisions, as well as during the implementation of programs having the potential to contribute to visibility im pairment in mandatory Class I areas. The progress and Plan reviews

are to occur at five

- year intervals, with a progress report between each required P lan revision. This consultation process shall provide on-going and timely opportunities to address the status of the control programs identified in this SIP, the development of future assessments of sources and impacts, and the development of additional control programs. The consultation will include the status of the following specific implementation items:

1. Implementation of emissions strategies identified in the SIP as contributing to achieving improvement in the worst- day visibility.

2. Summary of major new permits issued.

3. Status of State actions to meet commitments for completing any future asse ssments or rulemakings on sources identified as likely contributors to visibility impairment, but not directly addressed in the most recent SIP revision.

4. Any changes to the monitoring strategy or monitoring stations status that may affect tracking of re asonable progress. 5. Work underway for preparing the 5-year review and/or 10- year revision. 6. Items for FLMs to consider or provide support for in preparation for any visibility protection SIP revisions (based on a 5-year review or the 10-year revision schedule under EPA’s RHR)

. 7. Summary of topics discussion (meetings, emails, other records) covered in ongoing communications between the State and FLMs regarding implementation of the visibility

program.

The consultation will be coordinated with the designated visibility protection program coordinators for the National Park Service, U.S. Fish and Wildlife Service, Bureau of Land Management, and the U.S. Fore st Ser vice. At a minimum, the State of Wyoming will meet with the Federal Land Managers on an annual basis through the We stern Regional Air Partnership or an alternative Regional Planning Organization

.

11.3 Tribal Consultation

Although tribal consultation is not required under the Regional Haze Rule, the Division views this as an important part of the consultation process, and actively pursued this during the development of the R egio nal Haze P lan. Not unlike the state consultation process, consultation with tribes involved reviewing major emission sources and regional haze strategies to address

visi bility issues. Consultation correspondence between Wyoming and tribal contacts will be included in Chapter 11 of the Wyoming TSD.187 

### CHAPTER 12 DETERMINATION OF THE ADEQUACY OF THE EXISTING PLAN

Depending on the findings of the five- year progress rep ort, Wyoming commits to taking one of the actions listed in 40 CFR 51.308(h). The findings of the five- year progress report will determine which action is appropriate and necessary.

List of Possible Actions (40 CFR 51.308(h))

1. The Division determines that the existing SIP requires no further substantive revision in

order to achieve es tablished goals. The Division provides to the EPA Administrator a negative declaration that further revision of the SIP is not needed at this time.

2. The Division determines that the existing SIP may be inadequate to ensure reasonable progress due to emissions from other states, which participated in the regional planning process. The Division provides notification to the EPA Administrator and the states that participat ed in regional planning. The Division collaborates with states and FLMs through the regional planning process to address the SIP’s deficiencies.

3. The Division determines that the current SIP may be inadequate to ensure reasonable progress due to emissi ons from another country. The Division provides notification, along with available information, to the EPA Administrator.

4. The Division determines that the existing SIP is inadequate to ensure reasonable progress

due to emissions within the state. The Division will consult with FLMs and revise its SIP to address the Plan’s deficiencies within one year.188 

### CHAPTER 13

TECHNICAL INFORMATION AND DATA RELIED UPON IN THIS PLAN

This chapter describes the informati on relied upon by the Division in developing this Regional

Haze Plan. T he first portion of this chapter describes the Western Regional Air Partnership (WRAP) and the work products of this organization which have been utilized by the Division

.

13.1 The WRAP and Technical Support

T he WRAP is a voluntary organization of western states, tribes and Federal agencies which was formed in 1997 as the successor to the Grand Canyon Visibility Transport Commission (GCVTC). It is a regional planning organization that provides assistance to we stern s tates like Wyoming in the preparation and implementation of Regional Haze Plans. The WRAP is also instigating regional planning processe s to improve visibility in all W estern Class I areas by providing the technical and policy tools needed by state s and tribes to implement the Federal Regional Haze Rule. The WRAP is administered jointly by the Western Governors’ Association (WGA) and the National Tribal Environmental Council (NTEC).

The WRAP is comprised of western states, tribes and Federal agencies. The states include Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. Tribal board members include Campo Band of Kumeyaay Indians, Confederated Salish and Kootenai Tribes, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Native Village of Shungnak, Nez Perce Tribe, Northern Cheyenne Tribe, Orutsararmiut Native Council , Pueblo of Acoma, Pueblo of San Felipe, Pueblo of Zuni, and Shoshone-Bannock Tribes of Fort Hall. Representatives of other tribes participate on WRAP forums and committees. Participation is encouraged throughout the western states and tribes. Federal participants include the Department of Interior (National Park

Service and Fish & Wildlife Service ), the Department of Agriculture (Forest Service), and the Environmental Protection Agency.

13.2 WRAP Committees and Work G roups

• Air Managers Committee

The Air Managers Committee (formerly the Northern Air Man agers Committee) is made up of state and tribal caucuses, each representing the interests of state and tribal air managers. The

c ommittee is expected to provide air managers with a forum for discussing WRAP related

matters of concern to them. These matters may cover a spectrum of air quality issues. The committee also provides a mechanism for communication and guidance to the technical and policy forums as to what air managers believe is needed to support their regional planning

efforts.

• Communications Committee

The WRAP Comm unications Committee facilitates the exchange of information between the standing committees and forums of the WRAP, and is also charged with developing materials189 that help the general public understand the WRAP process and take part in its decision making. Some of the products of the Communications Committee have included outreach materials to encourage direct participation, the development of internal and external communications plans

and the construction of the WRAP web site.

• Planning Team

The Planning Team is convened as needed to address long- term planning and administrative issues, such as annual WRAP work plans and the WRAP strategic plan. Some of the functions performed by the Planning Team were previously performed by the Coordinating Group, which no longer exists.

• Initiatives Oversight Committee

The Initiatives Oversight Committee (IOC) provides general oversight for the coordination and development of air quality strategies necessary to promote the implementation of the Grand Canyon Visibility Transport Commission’s recommendations. The IOC oversees the development of other air quality policies and strategies at the direction of the WRAP, refers issues to forums, reviews recommendations from forums and makes recommendations to the

WRAP.

• Techni cal Oversight Committee

The Technical Oversight Committee (TOC) provides general oversight to the technical activities of the WRAP. The TOC identifies technical issues and tasks necessary to support the activities

of the WRAP and refers these issues to the technical forums. The TOC identifies issues to be addressed by the forums, based on input, priorities, and directions from the WRAP. The TOC reviews any recommendations made by the forums and subsequently makes its own

recommendations to the WRAP.

• Im plementation Work Group

The purpose of the WRAP Air Managers Committee Implementation Work Group is to help

s tates and tribes prepare their Regional Haze Implementation Plans to meet the requirements of 40 CFR 51.308 and 401 CFR 51.309(g). The work group is comprised of state and tribal representatives to accommodate the needs of states and tribes by recognizing the variety of regulatory and statutory authorities and range of technical and policy expertise.

• Oil and Gas Emissions Work Group

Significant air pollutant emissions come from production of oil and gas from wells located on

state -regulated and tribal lands, as well as from the interconnected gathering networks interlacing the WRAP region. These emissions result from operation of an extensive fle et of field equipment and an array of processing plants, operating continuously across the West. These field operations include exploration, production, and gathering activities.190 His torically , emissions from large stationary point s ources processing thi s energy for the oil and gas fuels markets were pretty we ll quantified through existing regulatory a gency permitting programs, but quite a number of pieces of smaller oil and gas field equipment (compressor engines, drill rigs, heaters, dehydrators, flares

, etc .) traditionally fell below agency permitting

th resholds. Although individual emissions from this field equipment could be considered minor, with increasing energy demand and continuing oil and gas field development the cumulative

total s for oil and gas basins, producing states and the WRAP region as a whole were thought to present an entirely different picture. But prior to WRAP involvement, present and future area source emissions from western field oil and gas production operations were generally incompletely quantified.

The WRAP recognized this deficiency and formed the Oil and Gas Emissions Work Group to look more closely at this industry and take steps to address the deficiencies. In late 2005 th e WRAP completed the Phase I oil and gas emission inventory project to estimate for the first time, regional emission totals from these field operations. As a “first cut” Phase I had a number of uncertainties identified, thus the work group subsequently initiated the Phase II project, completed in f all 2007, to more fully characterize the oil and gas field o perations emissions. These WRAP inventories identified over 100,000 TPY of NO

x emissions in the WRAP region which had not previously been included in regional air quality assessments , as well as sig nificant totals of other air pollutant species (VOC’s primarily) critical in the evaluation of regional h aze and other air quality management issues.

Members of the Independent Petroleum Association of Mountain States (IPAMS) felt that still more improvem ent in the accuracy of these emission estimates was needed and available. So in late 2007 IPAMS initiated a Phase III regional oil and gas emission inventory project funded by their organization. The project was undertaken in conjunction with the WRAP to assure that the products from Phase III were widely distributed among non- industry stakeholders (state/local agencies, tribal air p rograms, Federal Land Managers, environmental groups and EPA). This wider participation was viewed as necessary to assure review and feedback such that the final inventories were understood and more universally accepted by those parties interested in and affected by oil and gas development in the Intermountain West.

• Tribal Data Development Work Group

The mission of this work group is to assist and advise WRAP on gathering tribal air quality data and other air quality issues related to the WRAP mission from tribes in the WRAP area. The y work with the other WRAP forum and non-tribal communities to improve understanding communities of protocols and processes for obtaining and using tribal data. In addition to assisting in gathering existing air quality an d air emissions data, this work group aids in devising plan s for filling the gaps in the tribal data.1 91 13.3 WRAP Forums

• Air Pollution Prevention Forum

The Air Pollution Prevention Forum (AP2) was created by the WRAP to examine barriers to use of renewable energy and energy efficient technologies, identify actions to overcome such barriers, and recommend potential renewab le energy and energy efficiency programs and policies that could result in a reduction of air pollution emissions from energy production and energy end -use sectors in the Grand Canyon Visibility Transport Region.

• Dust Emissions Joint Forum

In the summer of 2002, the WRAP Oversight Committees established a Dust Emissions Joint Forum to consolidate the WRAP’s efforts involving dust. Previously, three forums had worked on dust issues: the Mobile Sources Forum, the Research and Development Forum, and the

Em issions Forum. The new DEJF concentrate s on improving how dust emissions are estimated and subsequently treated by air quality models. The forum also examines strategies to effectively reduce the impact of dust emissions on visibility in Class I areas.

• Economic Analysis Forum

The mission of the Economic Analysis Forum (EAF) is to provide the WRAP and WRAP forums with projections of econometric parameters needed to forecast changes in emissions, and assessments of the economic effects of pollution controls on the region and sub-regions, including Indian Country. Specifically, the EAF is seeking to: develop a better definition of what states, tribes and stakeholders expect from the economic analyses provided with WRAP products; develop a common economic analysis framework, which will include incorporating existing studies’ economic analyses; assist states an d tribes as they prepare their I mplementation Plans; and provide overall analytical support and analysis as states and tribes gage th e economic

compon ents of their Regional Haze Plans.

• Emissions Forum

The Emissions Forum oversees the development of a comprehensive emissions tracking and forecasting system which can be utilized by the WRAP, or its member entities, monitors the

trends in actual emission s, and forecasts the anticipated emissions which will result from current regulatory requirements and alternative control strategies. In addition, this forum is responsible for the oversight of the assembly and quality assurance of the emissions inventori es and forecasts to be utilized by the WRAP forums.

• Fire Emissions Joint Forum

The Fire Emissions Joint Forum (FEJF) was formed to assist the WRAP in addressing the Grand Canyon Visibility Transport Commission’s (GCVTC) Recommendations on fire. The term fire refers inclusively to wildfire, prescribed natural fire/wildland fire managed for resource benefits, prescribed fire, and agricu ltural fire. The forum addresses a broad definition of smoke effects192 which includes consideration of public nuisance, pub lic health and visibility/r egional haze. The

FEJF follows its consensus based W ork Plan which addresses four major topics.

Criteria for implementation of different stringencies of smo ke management programs are being developed as well as specific smoke m anagement program e lements. Fire emissions are being directly assessed in terms of pollutant estimation methods, emission projectio ns and tracking.

A n assessment is being done of the potential applicability and utility of non- burning alternatives

to fire . The use of alternatives and other emission reduction methods relate s directly to the potential application of annual emission goals.

A public education and outreach program related to f ire and smoke effects is being developed.

All recommendations to t he WRAP and methods developed by the forum are intended for

We stern U.S. application and represent a consensus of FEJF members. Collaboration and cooperation with other entities addressing smoke management issues in the West have been

included in the Work Plan of the FEJF.

• Mobile Sources Forum

The Mobile Sources Forum (MSF) investigates and recommends mobile source emission control

measures. Mobile sources includes both on-road sources (e.g., cars, trucks, buses, and motorcycles) and off-road sources (e.g., aircraft and its support equipment, locomotives, commercial marine and pleasure craft, and equipment used for construction, logging, mining, agriculture, and lawn and garden care). Since emission standards for new on-road and off-road sources can only be set by the U.S. EPA (on-road standards can also be set by California), the MSF focuses more on the impact and treatment of existing sources, especially off-road sources. The MSF also participates in technical activities related to mobile sources. Duri ng its first couple of years (2000-02), the MSF led the development of a WRAP-wide mobile source emission inventory and worked with the Air Quality Modeling Forum to define and analyze the significance of mobile sources with respect to t he requirements of §309 of the Regional Haze

R

ule.

• Sources In and Near Class I Areas Forum

The Grand Canyon Visibility Transportation Commission (GCVTC) developed

recommendations to address emissions from sources in and near Class I areas on the Colorado

Plateau. The Sour ces In and Near Class I Areas Forum (In and Near Forum) help s implement those recommendations by working with parks and local communities to develop and implement strategies to minimize emissions and the resulting visibility impacts.

• Stationary Sources Jo int Forum

The Stationary Sources Joint Forum (SSJF) was established in January 2004 and replaces the Market Trading Forum (MTF). The SSJF focus es more broadly on stationary source issues throughout the WRAP and their relationship to Section 308 SIP requirements. Major topics for

the SSJF include BART, reasonable progress for stationary sources, technical analyses, and193 evaluating the effect of and integration with other regulatory and legislative developments at the

national level.

• Technical Analysis For um

The TAF coordinates and manage s the processing, display, delivery, and explanation of technical data for regional haze planning activities. The TAF assume s responsibility for combining the participants and maintaining the activities and ongoing projec ts of the Ambient Air Monitoring & Reporting Forum, the Air Quality Modeling Forum, and the Attribution of Haze Workgroup.

13.4 WRAP TSS

The primary purpose of the TSS is to provide key summary analytical results and methods documentation for the required technical elements of the Regional Haze Rule, to support the preparation, completion, evaluation, and implementation of the Regional Haze Implementation

P lans to improve visibility in Class I areas. The TSS provides technical results prepared using a regional approach, to include summaries and analysis of the comprehensive datasets used to identify the sources and regions contributing to regional haze in the Western Regional Air Partnership (WRAP) region.

The secondary purpose of the TSS is to be the one-stop-shop for access, visualization, analysis, and retrieval of the technical data and regional analytical results prepared by WRAP Forums and Workgroups in support of regional haze planning in the West. The TSS specifically summarizes results and consolidates information about air quality monitoring, meteorological and receptor modeling data analyses, emissions inventories and models, and gridded air quality/visibility regional modeling simulations. These copious and diverse data are integrated for ap plication to air quality planning purposes by prioritizing and refining key information and results into explanatory tools. A detailed description of the TSS website, “WRAP Technical Support System Web Site Description (November 16, 2009 Draft) ”, can be f ound in Chapter 13 of the Wyoming

TSD.

13.5 IMPROVE Monitoring

13.5.1 Background on IMPROVE Monitoring

The Interagency Monitoring of Protected Visual Environments (IMPROVE) program is a cooperative measurement effort governed by a steering committee c omposed of representatives from Federal and regional -state organizations. The IMPROVE monitoring program was

established in 1985 to aid the creation of Federal and State Implementation P lans for the protection of visibility in Class I areas (156 national parks and wilderness areas) as stipulated in

the 1977 amendments to the Clean Air Act.

The objectives of IMPROVE are: (1) to establish current visibility and aerosol conditions in mandatory C lass I areas; (2) to identify chemical species and emission s ources responsible for existing man

- made visibility impairment; (3) to document long

- term trends for assessing progress towards the national visibility goal; (4) and with the enactment of the Regional Haze194 Rule, to provide regional haze monitoring represen ting all visibility

- protected Federal C lass I areas where practical. IMPROVE has also been a key participant in visibility- related research, including the advancement of monitoring instrumentation, analysis techniques, visibility modeling, policy formulation and source attribution field studies.

An IMPROVE sampler, depicted below, consists of four separate modules used for collecting the various pollutant species.

Figure 13.5.1-1. Schematic of the I MPROVE Sampler Showing the F our Modules W ith Separate Inlets and P umps

( http://vista.cira.colostate.edu/improve/Overview/IMPROVEProgram_files/frame.htm )

The IMPRO VE monitoring network consists of aerosol and optical samplers. The network began operating in 1988 with 20 monitoring sites in Class I a rea s. By 1999 the network expanded to 30 monitoring sites in Class I areas and 40 sites using IMPROVE site and sampli ng protocols operated by F ederal and S tate agencies. With the enactment of the Regional Haze Rules the IMPROVE network has been expanded by 80 new sites. Photographs of Wyoming Class I area IMPROVE monitoring sites are provided in Chapter 2

.

13.6 Form ula for Reconstructed Light Extinction

The IMPROVE program has developed methods for estimating light extinction from speciated aerosol and relative humidity data. The three most common metrics used to describe visibility impairment are:

 Extinction (b

ex t )

- Extinction is a measure of the fraction of light lost per unit length along a sight path due to scattering and absorption by gases and particles, expressed in inverse Megameters (Mm -1 ). This metric is useful for representing the contribution of195 each aerosol species to visibility impairment and can be practically thought of as the units of light lost in a million meter distance.

 Visual Range (VR)

- Visual range is the greatest distance a large black object can be seen on the horizon, expressed in kilo meters (km) or miles (mi).

 Deciview (dv)

- This is the metric used for tracking regional haze in the Regional Haze Rule. The deciview index was designed to be linear with respect to human perception of visibility. A one deciview change is approximately equivalent to a 10% change in extinction, whether visibility is good or poor. A one deciview change in visibility is generally considered to be the minimum change the average person can detect with the naked eye.

The IMPROVE network estimates light extin ction based upon the measured mass of various contributing aerosol species. EPA’s 2003 guidance for calculating light extinction is based on the original protocol defined by the IMPROVE program in 1988. (For further information, see http://vista.cira.colostate.edu/improve/Publications/GuidanceDocs/guidancedocs.htm .) In December 2005, the IMPROVE Steering Committee voted to adopt a revised algorithm for use by IMPROVE as an alternative to the original approach.

The revised algorithm for estimating light extinction is calculated as recommended for use by the IMPROVE steering committee using the following equations:

b ext ≈ 2.2 x f

s (RH) x [Small Amm. Sulfate] + 4.8 x f L (RH) x [Large Amm. Sulfate]

+ 2.4 x f

s (RH) x [Small Amm. Nitrate] + 5.1 x f L (RH) x [Large Amm. Nitrate] + 2.8 x [Small POM] + 6.1 x [Large POM] + 10 x [EC] + 1 x [Soil]

+ 1.7 x f

ss (RH) x [Sea Salt]

+ 0.6 x [CM] + 0.33 x [NO 2 (ppb)] + Rayleigh Scattering (Site Specific)

The revised algorithm splits ammonium sulfate, ammonium nitrate, and POM concentrations into small and large size fractions as follows:196 13.7 Wyoming IMPROVE Monitoring Network

In Wyoming there are three IMPROVE monitors which are described in the table below. There are seven Class I areas in Wyoming; therefore, some monitors serve multiple Class I areas. Although it is desirable to have one monitor for each Class I area, in most cases one monitor is “representative” of haze conditions in nearby Class I areas. Locations and descriptions of the IMPROVE monitors were presented in Chapter 2.

Table 13.7-1. The Wyoming IMPROVE Monito ring Network

Site Code Class I Area Sponsor Elevation (MSL) Start Date

BRID1 Bridger Wilderness Fitzpatrick Wilderness USFS 2627 m

8619 ft 3/2/1988

NOAB1 North Absaroka Wilderness

Washakie Wilderness USFS 2483 m

8146 ft 1/25/2000

YELL2 Grand Teton Natio nal Park

Teton Wilderness

Yellowstone National Park NPS 2425 m

7956 ft 7/1/1996